Mark Strage

Prof. Holzer
Fundamentals of Law Practice 1
9/16/18

Voluntary Confession Test- (1): Personal Characteristics

The defendants’ personal characteristics: their limited education level, lack of

experience with law enforcement, and youth were factors the Quartararo and Lewis courts

relied upon in finding the confessions to be involuntary under the totality of the circumstances.

“Lewis, at the time of his confession, was a young 22-year old black man of limited education

with apparently little prior experience with police methods.” Lewis . Similarly in Quartararo,

“Petitioner, a juvenile who had no prior experience with the criminal process, was subjected to

lengthy incommunicado interrogation in violation of New York law.” Quartararo. Peter

Quartararo was 15 years old, Alfred Lewis was 22 years old, both had only attained a 9th grade

education level. Lewis had had limited contact with the police and Quartararo none at all. Both

courts found that the defendants’ age, inexperience and low education level contributed to

their lack of free will and precluded their ability to competently deal with the pressure of the

conditions of interrogation and the conduct of the police.