Brown v. Mississippi

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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. 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, and were the only evidence used in the subsequent one-day trial. The defendants were convicted by a jury and sentenced to be hanged. 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 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.

Aftermath

Upon remand from the United States Supreme Court, the three defendants pleaded nolo contendere to manslaughter rather than risk a retrial. They were 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.

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