Law School Case Brief
Brown v. Mississippi - 297 U.S. 278, 56 S. Ct. 461 (1936)
A complaint that a conviction was obtained by confessions procured through the use of torture is not of the commission of mere error, but of a wrong so fundamental that it made the whole proceeding a mere pretense of a trial and renders the conviction and sentence wholly void.
Defendants Brown and others were indicted for the murder of one Raymond Stewart, whose death occurred on March 30, 1934. They were indicted on April 4, 1934, and were then arraigned and pleaded not guilty. Counsel were appointed by the court to defend them. Trial was begun the next morning and was concluded on the following day. At trial, aside from the confessions, there was no evidence sufficient to warrant the submission of the case to the jury. After a preliminary inquiry, testimony as to the confessions was received over the objection of defense counsel. Defendants then testified that the confessions were false and had been procured by physical torture. The case went to the jury with instructions, upon the request of defense counsel, that if the jury had reasonable doubt as to the confessions having resulted from coercion, and that they were not true, they were not to be considered as evidence. Defendants were found guilty and sentenced to death. On their appeal to the Supreme Court of Mississippi, defendants assigned as error the inadmissibility of the confessions. The judgment was affirmed.
Defendants filed a motion in the state supreme court to arrest the judgment and for a new trial on the ground that all the evidence against them was obtained by coercion and brutality known to the court and to the district attorney, and that defendants had been denied the benefit of counsel or opportunity to confer with counsel in a reasonable manner. The motion was supported by affidavits. At about the same time, defendants filed in the state supreme court a "suggestion of error" explicitly challenging the proceedings of the trial, in the use of the confessions and with respect to the alleged denial of representation by counsel, as violating the due process clause of the Fourteenth Amendment of the Constitution of the United States. The state supreme court entertained the suggestion of error, considered the federal question, and decided it against defendants' contentions. Defendants were granted a writ of certiorari.
Did the use of defendants' confessions at trial violate Due Process?
The Supreme Court of the United States reversed the judgment convicting defendants. The state's freedom to regulate the procedure of its courts was limited by the requirements of due process and did not include the freedom to obtain convictions that rested solely upon confessions obtained by violence. The use of defendants' confessions at trial was a clear denial of due process, rendering the convictions and sentences void. The failure of defendants' counsel to move to exclude the confessions did not prevent a reversal because the trial court was fully advised of the coerced nature of the confessions. The proceedings were vitiated by the lack of the essential elements of due process and could be challenged in any appropriate manner.
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