What is the current state of the law on involuntary confession and denial of due process?

In Lisenba v. California, 314 U.S. 219, 238, 62 S.Ct. 280, 291, 86 L.Ed. 166, the court, examining a claim of involuntary confession and resultant denial of due process, said: 'There are cases, such as this one, where the evidence as to the methods employed to obtain a confession is conflicting, and in which, although denial of due process was not an issue in the trial, an issue has been resolved by court and jury which involves an answer to the due process question. In such a case we accept the determination of the triers of fact, unless it is so lacking in support in the evidence that to give it effect would work that fundamental unfairness which is at war with due process.'

Elkins v. United States, supra, 364 U.S. 206, 224, 80 S.Ct. 1437, 1447, 4 L.Ed.2d 1669: 'In determining whether there has been an unreasonable search and seizure by state officers, a federal court must make an independent inquiry, whether or not there has been such an inquiry by a state court, and irrespective of how any such inquiry may have turned out. The test is one of federal law, neither enlarged by what one state court may have countenanced, nor diminished by what another may have colorably suppressed.'

In Malinski v. New York, 324 U.S. 401, at pages 416-417, 65 S.Ct. 781, at page 789, 89 L.Ed. 1029, Mr. Justice Frankfurter concurring said: 'The exact question is whether the criminal proceedings which resulted in his conviction deprived him of the due process of law by which he was constitutionally entitled to have his guilt determined. Judicial review of that guaranty of the Fourteenth Amendment inescapably

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