| Brown v. Mississippi | ||||||
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Supreme Court of the United States |
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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 | |||||
| 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 | ||||||
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| 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.
Contents |
Raymond Stuart, a white planter, was murdered 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. 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.
The opinion held that because the Fifth Amendment guarantees the defendant's protection from self-incrimination, a confession obtained through violence violates this protection. Further, the Fourteenth Amendment's Due Process clause was used to apply this provision of the Fifth Amendment to the states. This case was one in a series of cases in which parts of the Bill of Rights were deemed "fundamental" enough to apply to the states as well as to the federal government.
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.[1]
The prosecutor at the trial level, John Stennis, later served forty-two years as a United States senator. He ran for office in Mississippi thirteen times and never lost.