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The United States has long been a proponent of fair and equitable justice for all citizens. The Constitution of the United States declares that “all citizens are created equal” and shall be given equal protection under the law. Brown v. Mississippi (1936) is a pivotal case in U.S. history that demonstrates various procedural faults and erroneous judgments of the criminal justice system. Additionally, it speaks about the racial overtones of that era and what that meant for African Americans facing the criminal justice system.

Following a murder but prior to a court hearing, residents of Giles, Mississippi, prompted by law enforcement officers, including the sheriff, determined the guilt of the accused. The defendants, also known as the “Kemper County Trio,” were subjected to a trial, conviction, and attempted execution before they were arrested or indicted for the alleged crime of murder. The question that is central in this case is whether the convictions, which were based solely on coerced confessions— the only evidence of guilt—were obtained in a manner that was consistent with the due process clause of the Fourteenth Amendment of the U.S. Constitution.

Facts of the Case

Raymond Stuart of Giles, Mississippi, was murdered on March 30, 1934. His body was discovered at his home at 1:00 p.m. Stuart, a White farmer, had been brutally butchered with an axe. The then-deputy sheriff, Dial, was determined that he would find the killer(s). Eventually the investigation centered on Ed Brown, Henry Shields, and Arthur Ellington. Deputy Sheriff Dial went to the home of Arthur Ellington and then took the suspect to the scene of the crime. Upon their arrival, a mob of angry White men congregated and began to accuse Ellington. These individuals initiated the torment and torture of Ellington and insisted that Deputy Dial make Ellington confess. The mob, along with the law enforcement officers, tied a noose around Ellington's neck and hung him to get a confession. After releasing the suspect from the tree and hearing Ellington's protests of innocence, they hung him again. Ellington kept professing his innocence. This angered the mob, and they tied him to a tree and severely beat him. Despite his obvious pain, Ellington did not confess, and he was allowed to return home. However, on March 31, Deputy Dial and the mob returned, and Dial arrested Ellington, who still bore the strangulation marks of the execution attempted on the previous day. In returning to the county jail, Dial took Ellington through Alabama, where Dial whipped and tortured Ellington until he confessed to the murder of Stuart.

On April 1, 1934, Deputy Dial returned to the county jail where Ellington, Ed Brown, and Henry Shields were being held. Dial, along with a number of White men, made Brown and Shields remove their clothing and bend over a chair, where they were brutally beaten with metal buckles of leather straps until they confessed to the murder of Stuart, including exact details. During this beating, both Brown and Shields were told that the whippings would continue if they did not confess. Shortly afterward, Dial convened with another officer of the law and several witnesses to hear the confessions of the trio, and Brown and Shields were indicted.

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