297 U.S. 278 (1936), argued 10 Jan. 1936, decided 17 Feb. 1936 by vote of 9 to o; Hughes for the Court. In Brown v. Mississippi, the Supreme Court reversed the convictions of three African-American Mississippi tenant farmers for the murder of a white planter. At the trial, the prosecution's principal evidence was the defendants’ confessions to police officers. During the trial, however, prosecution witnesses freely admitted that the defendants confessed only after being subjected to brutal whippings by the officers. The confessions were nevertheless admitted into evidence; the defendants were convicted by a jury and sentenced to be hanged; and the convictions were affirmed by the Mississippi Supreme Court on appeal.
Aided by financial contributions from the National Association for the Advancement of Colored People and the Commission on Interracial Cooperation, ex-Mississippi governor Earl Leroy Brewer appealed the convictions to the U.S. Supreme Court, which the Court unanimously reversed under the Due Process Clause of the Fourteenth Amendment. Although reaffirming the fact that the Self-Incrimination Clause of the Fifth Amendment did not apply to the states, Chief Justice Charles Evans Hughes nevertheless held that a criminal conviction based upon confessions elicited by physical brutality violated the fundamental right to a fair trial mandated by the Due Process Clause. Brown began a line of cases involving the methods by which confessions were elicited from criminal defendants that culminated with Miranda v. Arizona (1966).
Richard C. Cortner