Brown v. Mississippi
| Brown v. Mississippi | |
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| Argued January 10, 1936 Decided February 17, 1936 |
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| Full case name | Brown, et al. v. State of Mississippi |
| Citations | 297 U.S. 278 (more) |
| Holding | |
| A defendant's confession that is extracted by police violence cannot be entered as evidence and violates the due process clause of the Fourteenth Amendment. | |
| Court membership | |
| Case opinions | |
| Majority | Hughes, unanimous |
Brown v. Mississippi, 297 U.S. 278, (1936), was a United States Supreme Court case that ruled that a defendant's involuntary confession that is extracted by police violence cannot be entered as evidence and violates the Due Process Clause of the Fourteenth Amendment.
Raymond Stuart, a white planter, was murdered in Kemper County, Mississippi on March 30, 1934. Arthur Ellington, Ed Brown, and Henry Shields, three black tenant farmers, were arrested for his murder. At the trial, the prosecution's principal evidence was the defendants' confessions to police officers. During the trial, however, prosecution witnesses freely admitted that the defendants confessed only after being subjected to brutal whippings by the officers.
One defendant had also been subjected to being strung up by his neck from a tree in addition to the whippings. The confessions were nevertheless admitted into evidence, and were the only evidence used in the subsequent one-day trial. The defendants were convicted by a jury and sentenced to be hanged. The convictions were affirmed by the Mississippi Supreme Court on appeal.
In a unanimous decision, the Court reversed the convictions of the defendants. The opinion was delivered by Chief Justice Hughes who wrote that "the transcript reads more like pages torn from some medieval account than a record made within the confines of a modern civilization." It held that a defendant's confession that was extracted by police violence cannot be entered as evidence and violates the Due Process Clause of the Fourteenth Amendment.
Upon remand from the United States Supreme Court, the three defendants pleaded nolo contendere to manslaughter rather than risk a retrial. They were however sentenced to six months, two and one-half years, and seven and one-half years in prison, respectively.
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