Brown v. Mississippi

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Following is the case brief for Brown v. Mississippi, United States Supreme Court, (1936)

Case summary for Brown v. Mississippi:

  • Brown was convicted of murder and sentenced to death based solely on his confession which was procured through severe beatings by the police.
  • Brown offered evidence of the beatings, but the court still permitted the confession to be introduced and considered by the jury.
  • In response, Brown challenged his conviction, claiming it violated his right to due process.
  • The Court held that the Due Process Clause applied to the states through the 14th Amendment and because the trial court had sufficient evidence the confessions were gained through improper measures, it wrongfully permitted use of the confessions as evidence.

Brown v. Mississippi Case Brief

Statement of the facts:

After trial, Brown was convicted of murder and sentenced to death. During the trial, Brown objected to the introduction of his confession, which he along with other co-defendants, alleged were procured as a result of severe beatings by the police. Witnesses were called to testify to the police beatings and the other men still had visible scars at the time of the trial. Aside from the confessions, no evidence existed that was sufficient to warrant the submission of the case to the jury. Despite this, the judge still submitted the case to the jury, instructing that if they had reasonable doubts as to the reliability of the confessions, that they should not be considered. Brown and the other men were still convicted.

Procedural History:

After trial, Brown appealed to the state supreme court, and the court affirmed the lower court’s decision. Brown then petitioned to the United States Supreme Court and the Court granted certiorari.

Rule of Law or Legal Principle Applied:

The 14th Amendment’s Due Process Clause requires state action to be consistent with fundamental principles of liberty and justice.

Issue and Holding:

Can convictions which rely exclusively on confessions induced by violence, comply with the 14th Amendment’s Due Process Clause? No.

Judgment:

The Court reversed the state supreme court’s judgment.

Reasoning:

The Court held that the “conviction and sentence were void for want of the essential elements of due process, and the proceeding thus vitiated could be challenged in any appropriate manner.”

When a confession is procured though violence, the evidence is not consistent with the Due Process Clause and is inadmissible at trial. The fundamental principles of justice are violated when severe beatings are used to get the accused to confess and violate due process.  In addition, when inappropriately procured confessions are the sole evidence against the defendants, the result is an unfair trial. Since the trial court had sufficient evidence the confessions were gained through coercion and brutality, the trial court wrongly permitted use of the confessions as evidence.

Significance:

Brown v. Mississippi helped shed light on the fact that sometimes federal constitutional rights apply to the states through the Due Process Clause of the 14th Amendment.

Student Resources:

https://supreme.justia.com/cases/federal/us/297/278/case.html
https://www.law.cornell.edu/supremecourt/text/297/278