In the 1962 case Haynes v. Washington, the U.S. Supreme Court ruled in favor of defendant Thomas James Haynes, overturning his conviction for robbery on grounds that it violated his Fifth Amendment rights against self-incrimination and Fourteenth Amendment right to due process. The police had obtained a confession from Haynes while he was held in custody without access to counsel or family members and after denying him several requests to call his wife until he "cooperated." The court found this treatment coercive enough to render any subsequent confession involuntary and therefore unconstitutional. This decision reinforced the importance of ensuring suspects' constitutional rights are upheld during interrogations, setting precedent for future cases involving coerced confessions.

In the dissenting opinion for Haynes v. Washington, Justice Clark argued that the majority had overstepped its bounds by reevaluating evidence and making determinations about credibility that should have been left to state courts. He contended that there was no clear proof of coercion or involuntary confession in this case as required by precedent. The defendant had not asked for an attorney nor did he indicate any desire to stop questioning, and his confession came after a reasonable period of time under non-threatening conditions. Furthermore, Justice Clark pointed out inconsistencies in Haynes' claims about being denied access to family members or legal counsel during interrogation which were contradicted by police testimony and phone records showing calls made from jail to his home on the day of arrest. In conclusion, he believed it was inappropriate for federal courts to interfere with state court judgments unless there is convincing evidence they are incorrect; something he felt was lacking here.