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Brown v. Mississippi

Law Dictionary

Law Dictionary

Featuring Black's Law Dictionary 2nd Ed.
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Criminal Procedure keyed to Weinreb

Citation. Brown v. Mississippi, 297 U.S. 278, 56 S. Ct. 461, 80 L. Ed. 682, 1936 U.S. LEXIS 527 (U.S. Feb. 17, 1936)

Brief Fact Summary. Two individuals were convicted of murder, the only evidence of which was their own confessions that were procured after violent interrogation.

Synopsis of Rule of Law. The Fourteenth Amendment Due Process Clause is violated when a confession obtained via physical torture is used to convict a defendant.

Facts. The Petitioners were indicted for a murder that occurred on March 30, 1934. The Petitioners were indicted on April 4, 1934, arraigned thereafter and then pleaded not guilty. The Petitioners were found guilty after a trial solely on the basis of their confessions. During the trial, the Petitioners testified that the confessions were untrue and procured after physical torture. The Petitioners appealed to the Supreme Court of Mississippi arguing that their Fourteenth Amendment rights were violated. The Supreme Court of Mississippi affirmed the trial court’s judgment.
The Mississippi Supreme Court concluded “(1) that immunity from self- incrimination is not essential to due process of law; and (2) that the failure of the trial court to exclude the confessions after the introduction of evidence showing their incompetency, in the absence of a request for such exclusion, did not deprive the defendants of life or liberty without due process of law; and that even if the trial court had erroneously overruled a motion to exclude the confessions, the ruling would have been mere error reversible on appeal, but not a violation of constitution right.”
The state’s highest court also observed “[a]fter the state closed its case on the merits, the appellants, for the first time, introduced evidence from which it appears that the confessions were not made voluntarily but were coerced.”

Issue. “[W]hether convictions, which rest solely upon confessions shown to have been extorted by officers of the state by brutality and violence, are consistent with the due process of law required by the Fourteenth Amendment of the Constitution of the United States[?]”

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