In the case Brown v. Mississippi, the Supreme Court threw out a "voluntary" confession that was obtained after police officers repeatedly strung a suspect up in a tree and whipped him. The Court's decision was clear: Confessions obtained by force cannot be used as evidence at trial. By the 1950s, confessions were considered involuntary not only if police beat the suspect, but also if they held a suspect for an unnecessarily extended period of time, deprived him of sleep, food, water or bathroom facilities, promised some benefit if the suspect confessed or threatened some harm if he
