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Brown v. Mississippi

Supreme Court of the United States · 1936 · Criminal Procedure

Criminal ProcedureDue ProcessCoerced ConfessionsFourteenth Amendmentdue processcoerced confessiontorturestate officers

Facts

Petitioners were convicted of murder in a trial that began the morning after arraignment and ended the next day with death sentences. The only evidence sufficient to support submission to the jury was their confessions. The confessions were obtained by state officers and others through whipping, hanging, and threats of repeated violence until petitioners confessed in the form demanded. The trial court admitted the confessions despite undisputed evidence of coercion, and the convictions rested solely on those confessions.

Issue

Whether convictions that rest solely upon confessions shown to have been extorted by state officers through brutality and violence are consistent with the due process of law required by the Fourteenth Amendment. Also, whether the failure of defense counsel to renew a motion to exclude the confessions after proof of coercion prevents a due process challenge.

Rule

Although a State may regulate its own criminal procedure, it may not, consistent with due process, secure a conviction through a proceeding that is in substance a mere pretense of trial. A conviction resting solely on confessions obtained by violence or torture by state authorities denies due process of law under the Fourteenth Amendment and is void. Such a claim is not reduced to mere trial error by counsel's failure to make a further motion to exclude.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

In rural Georgia, deputies investigating an arson seized Malik Turner, beat him with a hose, and threatened to continue until he signed a statement they drafted. At trial in Macon, the prosecution offered the statement plus proof that a fire occurred, but no other evidence linked Malik to the crime.

If Malik is convicted solely on that statement, what is the strongest constitutional analysis?

Explanation. The controlling rule is that a state conviction resting solely on a confession obtained by brutality and violence from state officers denies due process under the Fourteenth Amendment. The majority distinguished ordinary compulsion through judicial process from torture used to extort a confession. When the only evidence tying the accused to the crime is such a confession, the proceeding is a mere pretense of trial and the conviction is void, not merely erroneous.