Brown v. Mississippi: Supreme Court Case, Arguments, Impact

Can forced confessions be used as evidence in court?

Scales of justice in a courtroom.

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In Brown v. Mississippi (1936), the Supreme Court unanimously ruled that, under the due process clause of the Fourteenth Amendment, forced confessions cannot be admitted into evidence. Brown v. Mississippi marked the first time the Supreme Court reversed a state trial court conviction on the basis that the defendants’ confessions were coerced.

Key Takeaways

  • In Brown v. Mississippi, the court ruled that forced confessions could not be used as evidence in court.
  • In the majority opinion, written by Chief Justice Hughes, the Supreme Court overturned a state conviction, enforcing its ability to regulate state judicial procedures if they conflicted with due process.
  • In the unanimous decision, the Supreme Court condemned the week-long apprehension, arraignment, and trial as a miscarriage of justice.

Facts of the Case

On March 30, 1934, police discovered the body of Raymond Stewart, a white Mississippian farmer. The officers immediately suspected three black men: Ed Brown, Henry Shields, and Yank Ellington. They detained and brutally beat all three men until each agreed to the version of the facts the police offered them. The defendants were arraigned, indicted, and sentenced to death within one week.

During the brief trial, the jury was not offered any evidence outside of the forced confessions. Each defendant took the stand to explain exactly how his confession was beaten out of him by the police. The Deputy Sheriff was called to the stand to rebut the testimony of the defendants, but he freely admitted to whipping two of the defendants. He was present when a group of men hung one of the defendants twice to force a confession. The defense attorneys failed to motion for the judge to exclude the forced confessions on the basis that the defendant’s rights had been violated.

The case was appealed to the Mississippi Supreme Court. The court decided not to reverse the conviction, on the basis that the defense attorney should have motioned to exclude the confession during the original trial. Two justices wrote passionate dissents. The U.S. Supreme Court took on the case under a writ of certiorari.

Constitutional Issues

Does the due process clause of the Fourteenth Amendment prevent prosecutors from using confessions that are shown to be forced?

The Arguments

Earl Brewer, former Governor of Mississippi, argued the case before the Supreme Court. According to Brewer, the state knowingly admitted coerced confessions, a violation of due process. The due process clause of the Fourteenth Amendment ensures that citizens are not deprived of life, liberty, or property without a proper legal process. Brewer argued that the trial for Ellington, Shields, and Brown, which lasted only a few days, failed to uphold the intent of the due process clause.

Attorneys on behalf of the state relied primarily on two cases, Twining v. New Jersey and Snyder v. Massachusetts, to show that the U.S. Constitution did not ensure a defendant's right against compulsory self-incrimination. They interpreted this as showing that the Bill of Rights did not offer citizens protection against forced confessions. The State also alleged that the fault lied with the defendants’ attorneys, who had failed to object to the forced confessions during the trial.

Majority Opinion

In a unanimous decision written by Chief Justice Charles Hughes, the court overturned the convictions, condemning the trial court failing to exclude confessions that were clearly obtained through torture.

Chief Justice Hughes wrote:

"It 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 court’s analysis focused on three aspects of the case.

First, the Supreme Court rejected the state’s argument that under Twining v. New Jersey and Snyder v. Massachusetts, the federal constitution does not protect a defendant from compulsory self-incrimination. The Justices reasoned that the cases were misused by the state. In those cases, the accused were compelled to take the stand and testify about their actions. Torture is a different type of compulsion and should be treated separately from the compulsion found in those cases.

Second, the Court acknowledged the right of the state to regulate trial procedures but argued that those procedures must not prevent due process of law. For example, a state may decide to stop the practice of trial by jury but may not replace a jury trial with “an ordeal”. The state may not knowingly present a “pretense” of a trial. Allowing the forced confessions to remain in evidence offered the jury a reason to convict the defendants, depriving them of life and liberty. The Supreme Court found that this was an offense against the fundamental principle of justice.

Third, the Court addressed whether the attorneys assigned to the defendants should have objected to the forced confessions when they were admitted into evidence. The Justices reasoned that the trial court was responsible for allowing clearly forced confessions to be admitted into evidence. A trial court is required to correct proceedings when due process has been denied. The burden of upholding due process falls on the court, not the attorneys.

Impact

Brown v. Mississippi called into question police methods used to obtain confessions from suspects. The original trial of Ellington, Shields, and Brown was a miscarriage of justice, based on racism. The Supreme Court ruling enforced the Court's right to regulate state judicial procedures if they violate due process.

Even though the Supreme Court overturned the convictions in Brown v. Mississippi, the case was thrown back down to state courts. After negotiations, each of the three defendants pled "no contest" to manslaughter charges, even though prosecutors failed to bring any evidence against them to light. Brown, Shields, and Ellington received varying sentences after time served, ranging from six months to seven and a half years.

Sources:

  • Brown v. Mississippi, 297 U.S. 278 (1936)
  • Davis, Samuel M. “Brown v. Mississippi.” Mississippi Encyclopedia, Center for Study of Southern Culture, 27 Apr. 2018, mississippiencyclopedia.org/entries/brown-v-mississippi/.