09/01/2026
In Brown v Mississippi, 297 U.S. 278 (1936), the United States Supreme Court held that the Due Process Clause of the Fourteenth Amendment, which provides that no state shall 'deprive any person of life, liberty, or property without due process of law . . .,' prevented the use of involuntary confessions in state trials. Subsequently, in Malloy v Hogan, 378 U.S. 1 (1964), the United States Supreme Court declared that additional protection against the use of involuntary confessions in state trials was afforded by the incorporation into the Due Process Clause of the Fourteenth Amendment, of the Fifth Amendment's protection against self-incrimination.