Brown v. Mississippi

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[?]”

Held.

The state argued that pursuant to Twining v. New Jersey the “exemption from compulsory self-incrimination in the courts of the states is not secured by any part of the Federal Constitution”. The state also relied on Snyder v. Massachusetts where the Supreme Court of the United States (“Supreme Court”) found “the privilege against self-incrimination may be withdrawn and the accused put upon the stand as a witness for the state.” The majority disregarded these arguments and observed “[b]ut the question of the right of the state to withdraw the privilege against self-incrimination is not here involved. The compulsion to which the quoted statements refer is that of the processes of justice by which the accused may be called as a witness and required to testify. Compulsion by torture to extort a confession is a different matter.”

Further, “[t]he state is free to regulate the procedure of its courts in accordance with its own conceptions of policy, unless in so doing it ‘offends some principle of justice so rooted in the traditions and conscience of our people as to be ranked as fundamental.’ ” However, “the freedom of the state in establishing its policy is the freedom of constitutional government and is limited by the requirement of due process of law.”

Here, “the trial equally is a mere pretense where the state authorities have contrived a conviction resting solely upon confessions obtained by violence.” Accordingly, “[t]he due process clause requires ‘that state action, whether through one agency or another, shall be consistent with the fundamental principles of liberty and justice which lie at the base of all our civil and political institutions.” Moreover, “[i]t would be difficult to conceive of methods more revolting to the sense of justice than those taken to procure the confessions of these petitioners, and the use of the confessions thus obtained as the basis for conviction and sentence was a clear denial of due process.”

The majority observed, “the trial court was fully advised by the undisputed evidence of the way in which the confessions had been procured. The trial court knew that there was no other evidence upon which conviction and sentence could be based. Yet it proceeded to permit conviction and to pronounce sentence. The conviction and sentence were void for want of the essential elements of due process, and the proceeding thus vitiated could be challenged in any appropriate manner.”

Discussion.

This case illustrates how federal constitutional rights also often times apply to the states through the Fourteenth Amendment Due Process Clause.