Brown v. Mississippi

Supreme Court of United States
297 U.S. 278 (1936)

ELI5:

Rule of Law:

A conviction in a state court which rests solely upon confessions shown to have been extorted by state officers through brutality and violence is a clear denial of due process required by the Fourteenth Amendment.

Facts:

On March 30, 1934, Raymond Stewart was murdered.
That night, a deputy sheriff, Dial, and other white men accused one of the petitioners, Ellington, of the crime.
When Ellington denied his involvement, the men hung him by a rope from a tree, let him down, hung him again, and then whipped him.
A day or two later, Deputy Dial arrested Ellington, drove him into Alabama, and whipped him until he agreed to confess to a dictated statement.
The other two petitioners, Brown and Shields, were arrested and taken to jail.
At the jail, a deputy and others made Brown and Shields strip and then whipped their backs "to pieces with a leather strap with buckles on it."
The whippings continued until Brown and Shields confessed to the details demanded by their torturers.
The petitioners were warned that if they ever changed their story, they would receive the same treatment again.

Procedural Posture:

Petitioners Ellington, Brown, and Shields were indicted for murder in a Mississippi state trial court.
At trial, the court admitted their confessions into evidence over the objections of defense counsel.
The jury found the petitioners guilty, and the trial court sentenced them to death.
Petitioners appealed to the Supreme Court of Mississippi, which affirmed the convictions.
Petitioners then filed a "suggestion of error" with the Mississippi Supreme Court, arguing that the use of the coerced confessions violated the Due Process Clause of the Fourteenth Amendment.
The Mississippi Supreme Court considered the federal question but again affirmed the convictions.
The U.S. Supreme Court granted a writ of certiorari to review the decision of the Mississippi Supreme Court.

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Issue:

Does the use of confessions obtained through physical torture by state officers to secure a conviction in a state court violate the Due Process Clause of the Fourteenth Amendment?

Opinions:

Majority - Mr. Chief Justice Hughes

Yes, a conviction based on confessions obtained by torture is a clear denial of due process. The state's freedom to regulate its own court procedures is limited by the fundamental principles of justice required by the Fourteenth Amendment's Due Process Clause. While states can modify many procedural rights, they cannot substitute trial by ordeal for trial by witness. A trial is a "mere pretense" when state authorities contrive a conviction resting solely upon confessions obtained by violence. Such methods are "revolting to the sense of justice" and make the entire proceeding void, rising above mere procedural errors like the defense's failure to make a specific motion to exclude the evidence after it was admitted.

Analysis:

This landmark decision was the first time the Supreme Court held that a conviction in a state court based on a coerced confession violates the Fourteenth Amendment's Due Process Clause. It effectively began the process of incorporating aspects of the Fifth Amendment's protection against self-incrimination to the states through the Fourteenth Amendment. The ruling established federal judicial oversight over state criminal proceedings to ensure they meet a standard of fundamental fairness, preventing states from using evidence obtained through physical brutality to secure convictions.

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