In Brown v. Mississippi, 297 U.S. 278 (1936), the Court ruled that confessions obtained as a result of coercion and brutality by law enforcement officers are violative of the due process clause of the fourteenth amendment and are therefore inadmissible in court. Miranda v. Arizona, 384 U.S. 436 (1966), stated that evidence obtained by the police during custodial interrogation of a suspect cannot be used in court unless the suspect was informed of the following rights prior to the interrogation: (1) the right to remain silent; (2) that any statement made may be used in court of law; (3) the right to have an attorney present during questioning; and, (4) if the suspect cannot afford one, one will be appointed for him or her prior to questioning. And, as stated in Michigan v. Jackson, 475 U.S. 625 (1986), if the police initiate an interrogation after the defendant asserts his or her right to counsel at arraignment or similar proceedings, any waiver of that right for a police-initiated interrogation is invalid.