| Brown v. Mississippi | |
|---|---|
| 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 |
| Case history | |
| Prior | 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 opinion | |
| 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.
Raymond Stewart, a white planter, was murdered in Kemper County, Mississippi, on March 30, 1934. Three black tenant farmers — Arthur Ellington, Ed Brown, and Henry Shields — 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:
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. The only other evidence against any of the three was fingerprint evidence that linked Brown's fingerprints to the bowl of the lamp found near the body of the victim. [2] All three defendants were convicted of murder by a jury and sentenced to death by hanging. 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." [3] [2]
In a unanimous decision, the United States Supreme 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.
Upon remand from the United States Supreme Court, the three defendants pleaded nolo contendere to manslaughter rather than risk a retrial. Brown, the only defendant with any evidence against him beyond his confession, was sentenced to 10 years in prison. Ellington and Shields were sentenced to 5 years and 3 years in prison, respectively. All three men were given credit for time served. [4]
The prosecutor at the trial level, John C. Stennis, later served 42 years as a United States Senator, including two years as President pro tempore. He ran for office in Mississippi thirteen times and never lost.