State v. Moore recently held that only two proper grounds exist for excluding a confession from evidence in a criminal trial: That it was obtained in violation of the due process clause of the fourteenth amendment to the federal constitution or that it has not met the test provided by Washington statute. The Washington Constitution provides that, "no person shall be compelled in any criminal case to give evidence against himself . . ."' But the court held that this provision does not apply to the admissibility of confessions. The defendant had been convicted of second degree burglary and grand larceny. He sought reversal on the ground that, since he did not testify, admission of his confessions violated the self-incrimination provision.
Michael D. Garvey,
Washington Case Law,
Criminal Law—Admissibility of Confessions,
38 Wash. L. Rev.
Available at: https://digitalcommons.law.uw.edu/wlr/vol38/iss2/6