Brooks v. Florida
1967 U.S. LEXIS 4, 19 L. Ed. 2d 643, 389 U.S. 413 (1967)
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Rule of Law:
A confession is unconstitutionally involuntary and thus inadmissible at trial if it is obtained following a prolonged period of confinement under inhumane, coercive, and psychologically oppressive conditions that overbear the suspect's will.
Facts:
- On May 27, 1965, a disturbance occurred at the Florida prison where Bennie Brooks was an inmate.
- On the same day, Brooks and two other prisoners were confined to a small punishment cell, described as 7 feet by 6.5 feet.
- The cell had no external window, no bed or other furnishings, and only a hole in the floor that served as a commode.
- For 14 consecutive days, Brooks was held naked in this cell.
- During this confinement, Brooks was fed a 'restricted diet' consisting of four ounces of soup and eight ounces of water three times per day.
- His only human contact during this period was with the prison's investigating officer.
- On the 15th day, Brooks was taken directly from the punishment cell to the investigating officer for questioning.
- Shortly after the questioning began, Brooks confessed to his involvement in the riot, and his statement was recorded.
Procedural Posture:
- Bennie Brooks was convicted of participating in a riot in a Florida state trial court.
- Brooks appealed to the Florida District Court of Appeal, First District, which affirmed his conviction without a written opinion.
- Brooks then filed a petition for a writ of certiorari in the Florida Supreme Court, which dismissed the petition without opinion.
- Brooks then petitioned the United States Supreme Court for a writ of certiorari.
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Issue:
Is a confession voluntary and admissible when it is obtained from a prisoner immediately after he was held naked in a small, barren punishment cell with two other inmates for 14 days on a diet of thin soup and water?
Opinions:
Majority - Per Curiam
No. A confession cannot be considered the voluntary expression of an uncoerced will when it is extracted immediately after a prisoner has been subjected to prolonged, barbaric conditions of confinement. The court reviewed the totality of the circumstances, finding the 'stark facts' of Brooks's confinement—being held naked for two weeks in a barren, windowless 'sweatbox' with two other men on a near-starvation diet—created such an oppressive environment that it tainted the subsequent confession. Citing a long line of cases beginning with Brown v. Mississippi, the Court reiterated that the Constitution does not permit prosecutorial use of an involuntary confession and that it has an independent responsibility to examine the record to make that determination. The conditions documented in the record constituted a 'shocking display of barbarism' that rendered the confession involuntary as a matter of law.
Concurring - Justice Black
Justice Black concurred in the result without a written opinion.
Analysis:
This case reinforces the 'totality of the circumstances' test for determining the voluntariness of a confession. It clarifies that coercion leading to an involuntary confession can be entirely psychological and environmental, without the need for direct physical violence or threats. The Court's decision emphasizes its role in independently reviewing the factual record to guard against constitutional violations, particularly in the inherently coercive setting of a prison. This precedent serves as a powerful example of confinement conditions so extreme that they presumptively render any resulting confession involuntary and inadmissible.
