In the case of Rogers v. Richmond, Warden (1960), the Supreme Court ruled that a confession obtained through coercion is inadmissible as evidence. The defendant, Richard Rogers, was convicted for murder based on his own confession which he claimed was coerced by police threats to arrest his ill wife if he did not confess. The Connecticut Supreme Court upheld the conviction stating that while it would have been better if no threat had been made, there was no actual harm done since they didn't follow through with their threat and therefore the confession wasn't coerced. However, upon appeal to the U.S Supreme Court, it held that whether or not a confession is voluntary should be determined from an objective perspective rather than subjective intent of law enforcement officers involved in obtaining confessions. It concluded that any form of psychological pressure applied by law enforcement officials could potentially render a suspect's statement involuntary and thus inadmissible under due process clause of Fourteenth Amendment.

In the dissenting opinion for Rogers v. Richmond, Justice Whittaker argued that the majority had overstepped its bounds by creating a new rule of law without proper justification or precedent. He contended that it was not within the Court's power to decide whether a confession was coerced based on their own subjective judgment of what they would have done under similar circumstances. Instead, he believed this determination should be left to juries and lower courts who are better equipped to evaluate the facts and circumstances surrounding each individual case. Furthermore, he disagreed with the majority's assertion that psychological coercion could invalidate a confession in absence of physical brutality or threat thereof; arguing instead that such an expansive interpretation could potentially render all confessions inadmissible as evidence due to inherent pressures associated with police interrogation.