Brown v. Mississippi
In Brown v. Mississippi, 297 U.S. 278 (1936), the Court held that convictions based upon tortured confessions could not stand, but it identified the Due Process Clause, and not the Self-Incrimination Clause, as the source for its ruling. Id., at 285.
The Court interpreted the Self-Incrimination Clause as limited to "the processes of justice by which the accused may be called as a witness and required to testify. Compulsion by torture to extort a confession is a different matter." Ibid.
The decision in Brown antedated the incorporation of the Clause and the ensuing understanding of its fundamental role in our legal system.