The issues of voluntariness and application of the self-incrimination clause have swayed back and forth for years between a strict standard and one that freed the hands of the police. Standards were established, modified, and later reestablished in more than 150 years of litigation. By the mid-1960s the application of the Fifth Amendment in confession cases was chaotic. Invocation by the Court of a selfincrimination standard for judging the fruits of police interrogation was no unheralded novelty by the time of

Miranda v. Arizona