Brady v. Maryland, 373 U.S. 83 (1963)
In the case of Brady v. Maryland, a significant ruling by the United States Supreme
Court in 1963, the principle established was that prosecutors must disclose evidence
favorable to the defendant in criminal cases. John Brady and his accomplice were
convicted of murder and sentenced to death in Maryland. During the trial, Brady’s
defense attorney requested all statements made by the accomplice to the police.
However, the prosecutor only revealed the accomplice’s oral confession, withholding
statements that contradicted Brady’s involvement in the crime. Brady’s conviction was
upheld by the Maryland Court of Appeals, which ruled that the suppression of evidence
did not violate his constitutional rights. Subsequently, the case was appealed to the U.S.
Supreme Court. The primary issue addressed was the Prosecutorial Duty to Disclose
Favorable Evidence: whether the prosecution's failure to disclose exculpatory evidence
violated Brady's due process rights under the Fourteenth Amendment. The Supreme
Court held that suppression by the prosecution of evidence favorable to an accused
upon request violates due process where the evidence is material to guilt or
punishment. Additionally, the case raised questions about the disclosure of evidence
that could be used to impeach the credibility of government witnesses. Brady argued
that the withheld evidence, which contradicted his accomplice's testimony, could have
been used to challenge the witness's credibility and potentially sway the jury's decision.
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Giglio v. United States, 405 U.S. 150 (1972)
In Giglio v. United States, a case decided by the U.S. Supreme Court in 1972, further
clarification was provided regarding the prosecutor's duty to disclose evidence affecting
witness credibility. In this instance, Giglio was convicted of fraudulently using the U.S.
mails to defraud the government. During Giglio's trial, a key witness testified against him
in exchange for immunity from prosecution. However, the prosecutor failed to disclose
to Giglio's defense attorney the promise of immunity made to the witness. Giglio's
conviction was upheld on appeal, but the Supreme Court granted certiorari to consider
whether the prosecutor's failure to disclose the agreement with the witness violated
Giglio's constitutional rights. The central issue in Giglio v. United States was the
Disclosure of Witness Agreements: whether the prosecution's failure to disclose an
agreement made with a key witness violated the defendant's right to due process. The
Court held that the suppression of such evidence undermines the fairness of the trial
and violates the defendant's constitutional rights. The case also addressed the
Materiality of Evidence: emphasizing that evidence affecting the credibility of a witness
is inherently material to the defendant's case, regardless of whether the prosecution
believes it would affect the outcome of the trial.
United States v. Agurs, 427 U.S. 97 (1976)
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In United States v. Agurs, a case decided by the U.S. Supreme Court in 1976, further
standards for prosecutorial disclosure of evidence in criminal cases were clarified.
Agurs was convicted of murder in federal court. During his trial, his defense attorney
requested any evidence in the possession of the prosecution that might be favorable to
the defense. The prosecution provided some materials but did not disclose the criminal
record of a key witness for the prosecution. Agurs's conviction was upheld on appeal,
but the Supreme Court granted certiorari to address the adequacy of the prosecution's
disclosure. The primary issue of this case was the Standard for Prosecutorial
Disclosure: the standard by which the adequacy of prosecutorial disclosure should be
evaluated. The Court distinguished between cases where the defense specifically
requests evidence and cases where such requests are not made, applying different
standards for materiality in each scenario. Furthermore, the case addressed the
Materiality of Evidence in Different Contexts: holding that the prosecution's failure to
disclose evidence favorable to the defense violates due process only if the evidence is
material either to guilt or to punishment, depending on the specific circumstances of the
case.In United States v. Agurs, a case decided by the U.S. Supreme Court in 1976,
further standards for prosecutorial disclosure of evidence in criminal cases were
clarified. Agurs was convicted of murder in federal court. During his trial, his defense
attorney requested any evidence in the possession of the prosecution that might be
favorable to the defense. The prosecution provided some materials but did not disclose
the criminal record of a key witness for the prosecution. Agurs's conviction was upheld
on appeal, but the Supreme Court granted certiorari to address the adequacy of the
prosecution's disclosure. The primary issue of this case was the Standard for
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Prosecutorial Disclosure: the standard by which the adequacy of prosecutorial
disclosure should be evaluated. The Court distinguished between cases where the
defense specifically requests evidence and cases where such requests are not made,
applying different standards for materiality in each scenario. Furthermore, the case
addressed the Materiality of Evidence in Different Contexts: holding that the
prosecution's failure to disclose evidence favorable to the defense violates due process
only if the evidence is material either to guilt or to punishment, depending on the
specific circumstances of the case.
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References
Garrett, B. L. (2018). Convicting the Innocent: Where Criminal Prosecutions Go Wrong.
Harvard University Press.
Melamed, D. (2015). False Justice: Eight Myths that Convict the Innocent. Taylor &
Francis.
Resnick, D. J. (2017). Unfair: The New Science of Criminal Injustice. University of
California Press.
Thompson, J. E. (2018). Exposing the Criminal Justice System's Bias: From Policing to
Sentencing. Routledge.
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