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Brown v. Mississippi
Seal of the United States Supreme Court.svg
Argued January 10, 1936
Decided February 17, 1936
Full case name Brown, et al. v. State of Mississippi
Citations 297 U.S. 278 (more)
56 S. Ct. 461; 80 L. Ed. 682
Prior history Brown 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 brutality cannot be entered as evidence and violates the Due Process Clause of the Fourteenth Amendment to the Constitution of the United States of America.
Court membership
Case opinions
Majority Hughes, joined by unanimous
Laws applied
U.S. Const. amend. XIV

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 the use of force on the part of law enforcement cannot be entered as evidence and violates the Due Process Clause of the Fourteenth Amendment.

Facts of the case

Raymond Stewart, 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.

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 executed. The convictions were affirmed by the Mississippi Supreme Court on appeal. In Chief Justice Virgil Alexis Griffith's dissent, he wrote "the transcript reads more like pages torn from some medieval account than a record made within the confines of a modern civilization."

Judgment

In a unanimous decision, the Court reversed the convictions of the defendants. 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.

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

See also

  • Confession (legal)
  • Chambers v. Florida (1940)
  • List of criminal competencies
  • List of United States Supreme Court cases, volume 297
  • Miranda v. Arizona (1966)
  • Scottsboro Boys
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