## Facts

- Arthur Ellington, Ed Brown, and Henry Shields were indicted in Kemper County, Mississippi, for the murder of Raymond Stewart.
- The defendants pleaded not guilty, were tried promptly after indictment, and were convicted of murder and sentenced to death.
- State officers obtained purported confessions through severe physical abuse, including whipping with a leather strap and, for one defendant, being strung up by the neck from a tree.
- Prosecution witnesses acknowledged the confessions were produced by brutality and violence and were shaped to match the interrogators’ demands.
- Apart from the confessions, the record contained no evidence sufficient to warrant submitting the case to the jury.

## Issues

1. Whether a state criminal conviction that rests solely on confessions extorted by state officers through brutality and violence violates the Due Process Clause of the Fourteenth Amendment.
2. Whether admitting torture-produced confessions can be treated as a nonconstitutional evidentiary error insulated from federal constitutional review.

## Decision

- The U.S. Supreme Court unanimously reversed the Mississippi judgments.
- The Court held that murder convictions resting solely on confessions extorted by torture are void under the Due Process Clause of the Fourteenth Amendment.
- The Court rejected the view that admission of such confessions is merely a state-law evidentiary error where the convictions depend on them.

## Legal Principles

- Due process forbids state convictions based solely on confessions extracted by torture or physical violence by state officers.
- A trial is not constitutionally valid when the state secures a conviction through evidence “wrung from” the accused by brutality; constitutional guarantees concern the substance of fairness, not only procedural form.
- The Fourteenth Amendment due process analysis in this setting is distinct from questions about whether a state may compel testimony in court; the constitutional defect is the use of brutality and violence to procure evidence.
- State characterization of the admission of coerced confessions as “mere error” cannot preclude federal constitutional review when the method of obtaining the evidence destroys the essentials of due process.

## Conclusion

Because the defendants’ death sentences rested solely on confessions obtained through severe physical abuse by state officers, the proceedings lacked the essentials of due process, requiring reversal under the Fourteenth Amendment.


Brown v. Mississippi, 297 U.S. 278 (1936)