Brown v. Mississippi case brief summary
297 U.S. 278 (1936)
CASE FACTS
Defendants testified during their trial for murder that their confessions were false and had been procured by physical torture. Although a sheriff's deputy and two other participants admitted the allegations, defendants were convicted of murder and sentenced to death. The state supreme court affirmed the convictions. It denied defendants' motions for arrest of judgment and for a new trial and their suggestion of error asserting that the use of the confessions violated U.S. Constitutional Amendment XIV.
DISCUSSION
CONCLUSION
The court reversed the judgment affirming defendants' convictions and death sentences for murder. The use at trial of confessions coerced by physical torture as the basis for defendants' convictions violated the due process clause of the Fourteenth Amendment and rendered the convictions and sentences void.
Recommended Supplements for Criminal Procedure Criminal Procedure: Examples & Explanations, Sixth Edition
Emanuel Law Outline: Criminal Procedure
297 U.S. 278 (1936)
CASE SYNOPSIS
Defendants challenged a judgment of the
Supreme Court of Mississippi, which affirmed their convictions for
murder and denied their motions for an arrest of judgment and a new
trial. The state court also denied defendants' suggestion of error
alleging that the use at trial of confessions coerced from defendants
by physical brutality violated the due process clause of U.S.
Constitutional Amendment XIV.CASE FACTS
Defendants testified during their trial for murder that their confessions were false and had been procured by physical torture. Although a sheriff's deputy and two other participants admitted the allegations, defendants were convicted of murder and sentenced to death. The state supreme court affirmed the convictions. It denied defendants' motions for arrest of judgment and for a new trial and their suggestion of error asserting that the use of the confessions violated U.S. Constitutional Amendment XIV.
DISCUSSION
- The court granted certiorari and reversed.
- 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 the confessions 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.
CONCLUSION
The court reversed the judgment affirming defendants' convictions and death sentences for murder. The use at trial of confessions coerced by physical torture as the basis for defendants' convictions violated the due process clause of the Fourteenth Amendment and rendered the convictions and sentences void.
Recommended Supplements for Criminal Procedure Criminal Procedure: Examples & Explanations, Sixth Edition
Emanuel Law Outline: Criminal Procedure
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