" A hundred years earlier, in Hopt v. Utah, the Supreme Court ruled that a confession is not admissible if it is obtained by operating on the hopes or fears of the accused, and in doing so deprives him of the freedom of will or self-control necessary to make a voluntary statement. In 1897, the Court, in Bram v. United States, said that a statement must be free and voluntary, not extracted by any sorts of threats or violence or promises, however slight. A "

― John Grisham , The Innocent Man: Murder and Injustice in a Small Town