In Haley v. Ohio, a 15-year-old African American boy was convicted of murder based on a confession obtained after five hours of relentless questioning by police in the middle of the night without any legal counsel present. The Supreme Court overturned his conviction, ruling that it violated the Fourteenth Amendment's due process clause. The court held that age and intelligence are factors to be considered when determining whether someone has voluntarily confessed to a crime. It also emphasized that even though states have considerable latitude in devising procedures for criminal justice, these must not transgress fundamental principles of liberty and justice which lie at the base of our civil and political institutions.

In the dissenting opinion for Haley v. Ohio, Justice Frankfurter disagreed with the majority's decision to overturn Haley's conviction based on a coerced confession. He argued that there was insufficient evidence to prove coercion and that it should be left up to state courts to determine whether or not a confession is voluntary. Furthermore, he contended that even if Haley had been questioned without counsel present, this did not automatically render his confession involuntary under federal law at the time of his trial in 1938. The justice also expressed concern about setting a precedent where every juvenile defendant would require special protection during police questioning - something he believed could hinder effective law enforcement.