The U.S. Supreme Court case Payne v. Arkansas (1957) revolved around the issue of a coerced confession being used as evidence in court, which was argued to be a violation of due process under the Fourteenth Amendment. The petitioner, Olen Lee Payne, had been convicted for murder and sentenced to death based largely on his own confession while in police custody. However, it was later revealed that this confession may have been obtained through physical intimidation and psychological pressure by law enforcement officers who held him incommunicado for three days without advising him of his rights or allowing access to counsel or family members. The Supreme Court ruled 6-3 in favor of Payne, stating that confessions extracted through coercive means are not admissible as evidence because they violate constitutional protections against self-incrimination and deny defendants their right to fair trial procedures under the Due Process Clause.

The dissenting opinion in the Payne v. Arkansas case argued that the majority had failed to properly apply the due process clause of the Fourteenth Amendment. The dissenters believed that there was no clear evidence to support a finding of coercion or involuntary confession, and thus disagreed with overturning Payne's conviction based on these grounds. They pointed out inconsistencies in testimonies about alleged police brutality and suggested that any pressure felt by Payne could have been self-induced guilt rather than external coercion. Furthermore, they contended that even if some form of psychological pressure was applied, it did not necessarily render his confession involuntary under constitutional law standards at the time. Therefore, they concluded that there were insufficient grounds for deeming his confession unconstitutional and reversing his conviction.