Brown v. Mississippi

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)
Holding
A confession extracted through police violence cannot be entered as evidence and violates the Due Process Clause of the Fourteenth Amendment.
Court membership
Chief Justice
Charles E. Hughes
Associate Justices
Willis Van Devanter · James C. McReynolds
Louis Brandeis · George Sutherland
Pierce Butler · Harlan F. Stone
Owen Roberts · Benjamin N. Cardozo
Case opinions
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 police violence cannot be entered as evidence and violates the Due Process Clause of the Fourteenth Amendment.

Facts of the case

Raymond Stuart, a white planter, was murdered in Kemper County, Mississippi on March 30, 1934. Arthur Ellington, Ed Brown, and Henry Shields, three black tenant farmers, 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.

Judgment

In a unanimous decision, the Court reversed the convictions of the defendants. The opinion was delivered by Chief Justice Hughes who wrote that "the transcript reads more like pages torn from some medieval account than a record made within the confines of a modern civilization." 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 however sentenced to six months, two and one-half years, and seven and one-half years in prison, respectively.[1]

The prosecutor at the trial level, John Stennis, later served forty-two years as a United States senator. He ran for office in Mississippi thirteen times and never lost.

See also

References

  1. ↑ Neil R. McMillen, Dark Journey: Black Mississippians in the Age of Jim Crow, at 200 (University of Illinois Press 1990)

Further reading

  • Cortner, Richard C. (1986). A “Scottsboro” Case in Mississippi: The Supreme Court and Brown v. Mississippi. Jackson: University of Mississippi Press. ISBN 0-87805-284-4.
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