Note 920 — AMENDMENT 14 (continued 4)

338 U.S. 49, 61 (1949). In the 1949, 1950, and 1951 terms only one case arose which involved the forced confession issue in any significant way. This was Rochin v. California, 342 U.S. 165 (1952), which is discussed immediately below in another connection. See also Jennings v. Illinois, 342 U.S. 104 (1951); and Stroble v. California, 343 U.S. 181 (1952), in which diverse, but not necessarily conflicting, results were reached.