In the 1941 case Halliday v. United States, the Supreme Court ruled that a confession obtained from an accused person during illegal detention due to delay in arraignment is not admissible evidence. The defendant, William Halliday, was arrested and held for two days before being formally charged with bank robbery. During this time he confessed to his involvement in the crime. His lawyers argued that his confession should be excluded as it was made while he was illegally detained without charge or trial - a violation of Rule 5(a) of Federal Rules of Criminal Procedure which requires prompt arraignment after arrest. The court agreed and reversed Halliday's conviction on these grounds.

In the dissenting opinion for Halliday v. United States, Justice Frankfurter argued that the majority's decision was inconsistent with previous rulings and undermined the fundamental principles of justice. He contended that a confession obtained through coercion or intimidation should not be admissible in court, regardless of its truthfulness or relevance to the case at hand. According to him, allowing such evidence would encourage law enforcement officers to use improper methods during interrogations and could lead to wrongful convictions based on false confessions. Furthermore, he believed that it was impossible for judges to accurately determine whether a coerced confession had influenced a jury's verdict without asking them directly - something which is generally prohibited by legal rules and traditions. Therefore, he concluded that any trial where such evidence has been presented should automatically be considered unfair and its outcome invalid.