Brown v. Mississippi

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.

Brown v. Mississippi
Argued January 10, 1936
Decided February 17, 1936
Full case nameBrown, et al. v. State of Mississippi
Citations297 U.S. 278 (more)
56 S. Ct. 461; 80 L. Ed. 682
Case history
PriorBrown v. State, 173 Miss. 542, 161 So. 465, 158 So. 339 (1935); cert. granted, 296 U.S. 559 (1935).
Holding
A confession extracted through police violence cannot be entered as evidence and violates the Due Process Clause of the Fourteenth Amendment.
Court membership
Chief Justice
Charles E. Hughes
Associate Justices
Willis Van Devanter · James C. McReynolds
Louis Brandeis · George Sutherland
Pierce Butler · Harlan F. Stone
Owen Roberts · Benjamin N. Cardozo
Case opinion
MajorityHughes, joined by unanimous
Laws applied
U.S. Const. amend. XIV

Facts of the case

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:

"... defendants were made to strip and they were laid over chairs and their backs were cut to pieces with a leather strap with buckles on it, and they were likewise made by the said deputy definitely to understand that the whipping would be continued unless and until they confessed, and not only confessed, but confessed in every matter of detail as demanded by those present; and in this manner the defendants confessed the crime, and, as the whippings progressed and were repeated, they changed or adjusted their confession in all particulars of detail so as to conform to the demands of their torturers. When the confessions had been obtained in the exact form and contents as desired by the mob, they left with the parting admonition and warning that, if the defendants changed their story at any time in any respect from that last stated, the perpetrators of the outrage would administer the same or equally effective treatment."[1]

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.

Judgment

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.

Aftermath

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.[2]

The prosecutor at the trial level, John Stennis, later served forty-two years as a United States Senator, including 2 years as President pro tempore. He ran for office in Mississippi thirteen times and never lost.

See also

References
  1. "Brown v. Mississippi, 297 U.S. 278 (1936)". Justia US Supreme Court Center. February 17, 1936. Retrieved April 14, 2019.
  2. Neil R. McMillen, Dark Journey: Black Mississippians in the Age of Jim Crow, at 200 (University of Illinois Press 1990)

Further reading
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