In the 1910 Supreme Court case Holt v. United States, the court ruled that a confession obtained through physical torture was admissible as evidence in a trial. The defendant, Robert Hunter Holt, had been convicted of murder on the basis of his own confession which he claimed was extracted under duress and physical abuse by military officers. He appealed to the Supreme Court arguing that this violated his Fifth Amendment rights against self-incrimination. However, Justice Oliver Wendell Holmes Jr., writing for an unanimous court, held that while confessions induced by violence were not reliable and should be viewed with suspicion, they were not automatically excluded from consideration at trial if there was independent corroborating evidence supporting their truthfulness.

In the dissenting opinion for Holt v. United States, Justice Harlan argued that the jury should have been allowed to determine whether or not a confession was obtained under duress. He believed that this decision should not be left solely to the judge presiding over the case. Harlan stated that if there is evidence suggesting a confession may have been coerced, it's up to a jury - rather than just one individual - to decide its validity and admissibility in court proceedings. This perspective reflects his belief in safeguarding defendants' rights and ensuring fair trials by preventing potential abuses of power within judicial processes.