In the 1947 case of Lee v. Mississippi, the U.S. Supreme Court overturned a murder conviction on grounds that confessions had been obtained through police brutality and coercion, thus violating due process rights under the Fourteenth Amendment. The defendant, Willie Lee, was convicted for murder in Mississippi based largely on his confession which he claimed was extracted from him by force and without proper legal representation or warning of his constitutional rights. The state courts upheld this conviction despite these claims but when appealed to the Supreme Court it ruled in favor of Lee stating that such practices were unconstitutional as they violated fundamental fairness required by Due Process Clause of Fourteenth Amendment.

In the dissenting opinion for Lee v. Mississippi, Justice Hugo Black argued that the majority's decision to uphold a conviction based on confessions obtained through physical violence and coercion was in direct violation of due process under the Fourteenth Amendment. He contended that such methods were not only morally reprehensible but also legally unacceptable as they undermined the integrity of any subsequent trial proceedings. Furthermore, he expressed concern over potential implications this ruling could have on future cases involving coerced confessions or police brutality, fearing it might set a dangerous precedent where law enforcement agencies could use force with impunity to extract information from suspects. In his view, upholding convictions based on evidence gathered through these means would essentially condone state-sanctioned violence and erode fundamental constitutional protections against self-incrimination and cruel or unusual punishment.