Brady v. Maryland

373 U.S. 83 (1963).

A seminal United States Supreme Court opinion regarding prosecution’s obligation to disclose evidence in a criminal proceeding.

The facts of the case are as follows:  During his trial for first-degree murder, Brady admitted his participation in the underlying crime, but testified that his accomplice, Boblit, did the actual killing.  In his closing statement, Brady’s lawyer conceded that his client was guilty of first-degree murder, but asked the jury not to impose the death penalty.  The jury found Brady guilty of first-degree murder and Brady was sentenced to death.

Prior to trial, Brady’s attorney had asked the prosecution to allow him to examine Boblit’s statements.  The prosecution gave Brady’s counsel access to the statements, but withheld the one that indicated Boblit’s guilt in the actual killing.  That withheld statement was discovered only after Brady had been convicted.  Based on the prosecutor’s withholding of that statement, Brady moved for new trial, but the trial court denied that motion.

The issue presented to the United States Supreme Court was whether prosecution’s withholding of evidence that is material either to guilt or to punishment violates the due process guaranteed under the Fifth and Fourteenth Amendments to the United States Constitution.  The Court answered in the affirmative.

The Court held: “We agree with the Court of Appeals that suppression of [Boblit’s] confession was a violation of the Due Process Clause of the Fourteenth Amendment.”  The Court reasoned, “[t]his ruling is an extension of Mooney v. Holoham, 294 U.S. 103 (1935), where the Court ruled on what nondisclosure by a prosecutor violates due process: ‘It is a requirement that cannot be deemed to be satisfied by mere notice and hearing if a state has contrived a conviction through the pretense of a trial which in truth is but used as a means of depriving a defendant of liberty through a deliberate deception of court and jury by the presentation of testimony known to be perjured.  Such a contrivance by a state to prosecute the conviction and imprisonment of a defendant is inconsistent with the rudimentary demands of justice as is the obtaining of a like result by intimidation.”

The Court held that the prosecution must disclose all evidence in a criminal proceeding which is material either to guilt or to punishment.

In the instant case, the withheld evidence would not have exonerated Brady of the first-degree murder conviction, but was material and relevant to the punishment phase of the trial.  Thus, the Court remanded only for reconsideration of the issue of whether the death sentence imposed was proper with the new evidence that previously was not available to Brady.