The U.S. Supreme Court case Bram v. United States in 1897 revolved around the admissibility of a confession obtained under duress or coercion by law enforcement officers. The defendant, Alexander Bram, was accused and convicted for murder on an American vessel while at sea based primarily on his own confession to another crew member who was acting as an agent of the police force during questioning. The defense argued that this confession should not have been admitted into evidence because it had been coerced and therefore violated the Fifth Amendment's protection against self-incrimination. In its decision, the Supreme Court agreed with Bram's argument and overturned his conviction stating that any form of coercion or intimidation used to obtain a statement from someone suspected of committing a crime renders such statements inadmissible in court due to their involuntary nature.

In the dissenting opinion for Bram v. United States, Justice White argued that the majority misinterpreted both English common law and U.S. precedent in determining whether a confession was voluntary or not. He believed that they incorrectly applied an absolute standard of voluntariness rather than considering the totality of circumstances surrounding a confession. According to him, it is not enough to simply determine if there was any influence exerted on the defendant; instead, one must consider if such influence overbore the will of the accused and induced them to confess against their own self-interests. Furthermore, he disagreed with how much weight should be given to confessions obtained abroad under foreign legal systems when deciding admissibility in U.S courts.