## Facts

- A prison disturbance occurred on May 27, 1965, at a Florida state prison where Bennie Brooks was incarcerated.
- The same day, Brooks was placed for 35 days in a punishment cell (“sweatbox”) with two other inmates accused of rioting.
- The cell was windowless, had no bed or furnishings, and had only a hole in the floor used as a commode.
- Brooks was allegedly stripped naked before being placed in the cell; this testimony was not controverted.
- For the first 14 days, Brooks’s only outside contact consisted of interviews with the prison’s investigating officer.
- Brooks was kept on a restricted diet described as watery vegetables three times daily with limited water; his account was not controverted.
- On the 15th day, Brooks was taken directly from the punishment cell to the investigating officer, quickly confessed, and dictated a taped statement.
- The taped confession was introduced at trial, and Brooks was convicted of participating in a prison riot and sentenced to an additional nine years and eight months, consecutive to his existing sentence.
- Brooks alleged he was beaten while his statement was taken; the officer denied it and the trial judge disbelieved Brooks, but admitted the confession as voluntary.

## Issues

1. Whether a confession obtained after two weeks of confinement in extreme, degrading punishment-cell conditions was voluntary under the Fourteenth Amendment Due Process Clause.
2. Whether admitting such a confession at trial to secure a conviction is unconstitutional.

## Decision

- The Supreme Court granted certiorari and reversed in a per curiam decision.
- The Court held Brooks’s confession was involuntary under due process because it was the product of coercive punishment-cell conditions.
- The Court did not rely on the disputed allegation of a beating; the confinement conditions alone sufficed to render the confession involuntary.
- Because the confession was involuntary, its use at trial to convict Brooks was unconstitutional.

## Legal Principles

- A confession must be the “voluntary expression of an uncoerced will” to be admissible under the Fourteenth Amendment Due Process Clause.
- Voluntariness is evaluated under the totality of the circumstances, including conditions of confinement and the manner and setting in which questioning occurs.
- Extreme, degrading, and coercive confinement conditions can overbear a prisoner’s will even absent proven physical abuse during interrogation, making a subsequent confession inadmissible.

## Conclusion

The Supreme Court concluded that a confession obtained immediately after prolonged confinement in a “sweatbox” under barbaric, degrading conditions is involuntary under due process, and a conviction resting on such a confession cannot stand.


Brooks v. Florida, 389 U.S. 413 (1967)