In the 1940 case of Lisenba v. California, Robert S. Lisenba appealed his conviction for murder on grounds that his confession was obtained through physical violence and mental coercion by police officers, thus violating due process under the Fourteenth Amendment. The Supreme Court upheld the conviction in a 5-4 decision, ruling that while confessions extracted through brutality are unconstitutional, it is up to state courts to determine whether or not a confession was voluntary based on all circumstances surrounding it. In this case, despite allegations of abuse during interrogation sessions lasting several days with little food or sleep provided to him, both trial and appellate courts found no evidence supporting these claims after thorough examination of testimonies from involved parties including medical experts who examined Lisenba following his arrest.

In the dissenting opinion for Lisenba v. California, Justice Hugo Black argued that Robert James was denied a fair trial due to the use of coerced confessions and prejudicial evidence. He contended that James' confession was obtained through physical abuse and prolonged questioning by police officers, which violated his constitutional rights under the Fourteenth Amendment's Due Process Clause. Furthermore, he criticized the admission of evidence regarding crimes not charged in this case as it could have unduly influenced the jury against him. According to Justice Black, these factors combined resulted in an unfair trial process that did not uphold standards of justice or constitutional protections.