Cite as: 507 U. S. 680 (1993)
Opinion of the Court
in selection of grand-jury foreman, as this claim goes to the integrity of the judicial process).
Finally, and most importantly, eliminating review of Miranda claims would not significantly benefit the federal courts in their exercise of habeas jurisdiction, or advance the cause of federalism in any substantial way. As one amicus concedes, eliminating habeas review of Miranda issues would not prevent a state prisoner from simply converting his barred Miranda claim into a due process claim that his conviction rested on an involuntary confession. See Brief for United States as Amicus Curiae 17. Indeed, although counsel could provide us with no empirical basis for projecting the consequence of adopting petitioner's position, see Tr. of Oral Arg. 9-11, 19-21, it seems reasonable to suppose that virtually all Miranda claims would simply be recast in this way.5
If that is so, the federal courts would certainly not have heard the last of Miranda on collateral review. Under the due process approach, as we have already seen, courts look to the totality of circumstances to determine whether a confession was voluntary. Those potential circumstances include not only the crucial element of police coercion, Colorado v. Connelly, 479 U. S. 157, 167 (1986); the length of the interrogation, Ashcraft v. Tennessee, 322 U. S. 143, 153-154 (1944); its location, see Reck v. Pate, 367 U. S. 433, 441 (1961); its continuity, Leyra v. Denno, 347 U. S. 556, 561 (1954); the defendant's maturity, Haley v. Ohio, 332 U. S. 596, 599-601 (1948) (opinion of Douglas, J.); education, Clewis v. Texas, 386 U. S. 707, 712 (1967); physical condition, Greenwald v. Wisconsin, 390 U. S. 519, 520-521 (1968) (per curiam); and mental health, Fikes v. Alabama, 352 U. S. 191, 196 (1957). They also include the failure of police to advise the defendant of his rights to remain silent and to have counsel present
5 Justice O'Connor is confident that many such claims would be unjustified, see post, at 708-709, but that is beside the point. Justifiability is not much of a gatekeeper on habeas.
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