PA Supreme Court Suppresses Involuntary Confession
Posted in Constitutional Rights,Fifth Amendment on June 24, 2025
Background: The Case Against David Lukach
David Lukach was brought in to the police station for questioning regarding a suspicious death. During the nearly four-hour interrogation, police used several controversial tactics:
Lied about having strong evidence against him
Repeatedly told Lukach he was “not under arrest”
Implied that cooperating would help his situation
Took advantage of Lukach’s emotional state
Eventually, Lukach confessed. He later moved to suppress the confession, arguing it was not given voluntarily.
Was Lukach’s Confession Voluntary?
Under both the U.S. Constitution and the Pennsylvania Constitution, a confession must be the product of free will. The court had to evaluate whether the interrogation involved:
Deception or misrepresentation by police
Promises of leniency
Emotional or psychological manipulation
Signs of the suspect’s vulnerability or distress
The Pennsylvania Supreme Court’s Decision
The Court reversed the lower courts and found that Lukach’s confession was involuntary and unconstitutional. It cited:
False evidence ploys: Detectives misrepresented the strength of their case.
Repeated reassurances: Saying he was “not under arrest” created a false sense of freedom.
Psychological pressure: The interrogation wore down Lukach’s resistance.
Ultimately, the Court ruled that the confession was coerced and violated due process.
What This Means for Criminal Law in Pennsylvania
This case sets an important precedent in Pennsylvania:
Confessions must be scrutinized under the “totality of the circumstances.”
Psychological coercion can be just as damaging as physical force.
Law enforcement agencies must train officers to avoid overstepping constitutional boundaries during questioning.
- This decision does NOT mean that the police are not permitted to lie – Note another PA Supreme Court decision that upheld the right of the police to lie to a suspect to obtain a confession.
If you’re a criminal defense attorney, law student, or civil rights advocate, Commonwealth v. Lukach is a must-know decision.
Conclusion: Protecting Constitutional Rights During Interrogations
Commonwealth v. Lukach reaffirms that the ends do not justify the means in criminal investigations. When police use deceptive or manipulative tactics to extract confessions, the courts have a duty to intervene. The case underscores the importance of upholding due process and ensuring that justice is not compromised by coercion.
Need Legal Help?
If you or someone you know may have given a confession under questionable circumstances, speak to a qualified criminal defense attorney in Pennsylvania. Understanding your rights is the first step toward protecting them.
For a free case review, contact JD Law by email or leave a message at (814) 689-9139. Email is the preferred method of communication, as phone calls are directed to voicemail due to the high volume of spam and unsolicited calls.