Brown v. Mississippi
Citation and Court
297 U.S. 278 (1936) — Supreme Court of the United States
Facts
Three Black tenant farmers in Mississippi were convicted of murder solely on the basis of confessions. The confessions were obtained by a deputy sheriff and a mob of white men who hung the defendants from a tree, whipped them repeatedly, and told them they would be whipped until they confessed. The convictions were affirmed by the Mississippi Supreme Court.
Issue
Does the use at trial of a confession obtained through physical torture and brutal whipping violate the Due Process Clause of the Fourteenth Amendment?
Holding
Yes; a conviction based on a confession extorted by physical brutality is a denial of due process and cannot stand.
Rule / Doctrine
The Fourteenth Amendment’s Due Process Clause prohibits convictions based on confessions obtained through physical torture or coercion. Courts may not permit their processes to be used as instruments of such wrongdoing; the right to a fair trial includes the right not to be convicted by a confession wrung from the defendant by violence.
Significance
Brown v. Mississippi is the foundational case holding that physically coerced confessions violate the Due Process Clause, and the first in which the Supreme Court reversed a state criminal conviction on those grounds. It launched the voluntariness doctrine that governed confessions until Miranda (1966) and remains good law for the proposition that physically coerced confessions are absolutely inadmissible.