297 U.S. 278 (1936)
The petitioners Ellington, Ed Brown, and Henry Shields were indicted on April 4, 1934, for the murder of Raymond Stewart whose death had occurred on March 30, 1934.1 They were arraigned that day, pleaded not guilty, and the court appointed counsel to defend them.2 Their trial began the next morning and concluded the following day, resulting in convictions and death sentences.3
The prosecution's case rested entirely on confessions.4 These confessions were extracted through extreme physical violence inflicted by Deputy Sheriff Dial and other white men.5 On the night the crime was discovered, Dial and others seized Ellington at his home, hanged him from a tree twice, tied him to the tree and whipped him when he denied involvement, and later arrested him and whipped him again en route to jail until he agreed to confess as dictated.6
Brown and Shields were arrested and jailed.7 On the night of April 1, 1934, Dial and others came to the jail, forced the two men to strip, laid them over chairs, and whipped their backs with a leather strap with buckles until they provided confessions matching every detail demanded, changing their statements as the whippings continued.8 The following day, after allowing some recovery, sheriffs and others heard the confessions presented as voluntary, even though one defendant was limping and could not sit and rope marks were visible on another's neck.9
At trial the confessions were introduced over objection, the defendants testified to the coercion, and Dial admitted the whippings in rebuttal.10 The Mississippi Supreme Court affirmed the judgments.11 After the defendants filed a suggestion of error challenging the proceedings under the Fourteenth Amendment, the state court rejected the federal claim, prompting the United States Supreme Court to grant certiorari.
Whether convictions, which rest solely upon confessions shown to have been extorted by officers of the State by brutality and violence, are consistent with the due process of law required by the Fourteenth Amendment of the Constitution of the United States?12
The Due Process Clause of the Fourteenth Amendment prohibits a state from basing a conviction solely on a confession obtained through torture and violence by its officers.13 Such methods offend fundamental principles of liberty and justice so rooted in the traditions and conscience of our people as to be ranked as fundamental.14
No. The established facts demonstrate that the confessions of Ellington, Ed Brown, and Henry Shields were procured exclusively through repeated physical torture inflicted by Deputy Sheriff Dial and other white men, including multiple hangings from a tree, whippings with a leather strap containing buckles that cut their backs to pieces, and additional beatings administered until the defendants agreed to confess in every detail demanded.15 Aside from these confessions, no evidence existed that was sufficient to warrant submission of the case to the jury.16 The trial court was fully advised of the coercion through the defendants' testimony and Dial's own admissions yet permitted the convictions and death sentences to stand on that evidence alone.17 This substitution of the rack and torture chamber for the witness stand constitutes a clear denial of due process.18
Convictions resting solely upon confessions extorted by officers of the State through brutality and violence are inconsistent with the due process of law required by the Fourteenth Amendment.19
Whether the failure of the trial court to exclude the confessions after the introduction of evidence showing their incompetency, in the absence of a request for such exclusion, deprived the defendants of life or liberty without due process of law?20
When a trial court is fully advised by undisputed evidence that confessions were coerced by state officers, it must exclude them.21 Knowing that no other evidence supports conviction, the failure to exclude those confessions renders the entire proceeding a mere pretense of a trial and voids the conviction for want of due process.22 This holds regardless of whether defense counsel renewed a motion to exclude after the coercion was proved.23
Yes. Under the established facts, the confessions were introduced over objection, the defendants then testified that the statements were false and obtained by torture, and Deputy Dial admitted the whippings in rebuttal while the visible rope marks and limping were apparent to the court.24 The trial court knew these confessions formed the sole basis for any conviction yet proceeded to judgment and sentence without exclusion.25 This was not mere procedural error but a fundamental denial of due process that the state supreme court failed to correct despite the explicit Fourteenth Amendment challenge in the suggestion of error.26
The failure of the trial court to exclude the confessions after the introduction of evidence showing their incompetency deprived the defendants of life or liberty without due process of law.27