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  • Law School Case Brief

Brooks v. Florida - 389 U.S. 413, 88 S. Ct. 541 (1967)

Rule:

The Constitution does not permit prosecutorial use of an involuntary confession. In adjudicating the question of voluntariness, the court cannot escape the responsibility of making its own examination of the record.

Facts:

Petitioner Bennie Brooks was convicted in a Florida state court for participating in a riot in a Florida prison where he was an inmate. At the trial, his confession of guilt, obtained after his confinement in a barren punishment cell, where he subsisted on a very meager daily fare and was completely under the control and domination of his jailers, was admitted in evidence. His conviction was affirmed by the Florida District Court of Appeal, and his petition for writ of certiorari was dismissed by the Florida Supreme Court.

Issue:

Was the petitioner’s confession of guilt admissible as evidence, thereby warranting the petitioner’s conviction?

Answer:

No.

Conclusion:

Granting certiorari, the Supreme Court of the United States reversed the judgment of the Florida District Court of Appeal. The Court held that the petitioner’s confession was not the voluntary expression of an uncoerced will, and hence, not admissible in a state prosecution for petitioner’s participation in a riot in a prison, where prior to the confession the petitioner was for 2 weeks confined in a barren cage fitted only with a hole in one corner into which he and his cell mates could defecate, subsisted on a daily fare of 12 ounces of thin soup and 8 ounces of water, and saw not one friendly face from outside the prison, but was completely under the control and domination of his jailers.

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