Brady v. Maryland


373 U.S. 83 (1963) |
SCOTUS decided 1963-05-13
Jurisdiction level:

Suppression by the prosecution of evidence favorable to an accused who has requested it violates due process where the evidence is material either to guilt or to punishment, irrespective of the good faith or bad faith of the prosecution.

Result: Win
Importance:

From Wikipedia: Brady was given a new hearing, where his sentence was commuted to life imprisonment. Brady was ultimately paroled. He moved to Florida, where he worked as a truck driver, started a family and did not re-offend.

Police officers who have been dishonest are sometimes referred to as “Brady cops”. Because of the Brady ruling, prosecutors are required to notify defendants and their attorneys whenever a law enforcement official involved in their case has a confirmed record of knowingly lying in an official capacity.

Brady has become not only a matter of defendants’ due process trial rights, but also of police officers’ due process employment rights. Officers and their unions have used litigation, legislation, and informal political pressure to push back on Brady’s application to their personnel files. This conflict over Brady’s application has split the prosecution team, pitting prosecutors against police officers, and police management against police labor. Brady evidence also includes evidence material to credibility of a civilian witness, such as evidence of false statements by the witness or evidence that a witness was paid to act as an informant.

In United States v. Bagley (1985), the Court narrowed the reach of Brady by stating the suppressed evidence had to be “exculpatory” and “material” for a violation to result in the reversal of a conviction. Harry Blackmun wrote in Bagley that “only if there is a reasonable probability that, had the evidence been disclosed to the defense, the result of the proceeding would have been different. A ‘reasonable probability’ is a probability sufficient to undermine confidence in the outcome.”


Law type: Criminal
Topic(s): Due process, Prosecutorial conduct, and Suppression of evidence
State of origin: MD
Attorneys:

E. Clinton Bamberger, Jr. argued the cause for petitioner. With him on the brief was John Martin Jones, Jr. More about Clinton Bamberger: https://cnejl.org/item/clinton-bamberger-life/


Others involved:
Organization role:

Last modified: 2020-04-27 07:28
Case internal grade: A | Case internal status: OK |
Case internal status notes:
Collections:
Lists: Important cases

For more info: Findlaw

CASE DETAILS

(The syllabus is not part of the opinion, but is a summary prepared by the court reporter as a convenience.)

Syllabus

In separate trials in a Maryland Court, where the jury is the judge of both the law and the facts but the court passes on the admissibility of the evidence, petitioner and a companion were convicted of first-degree murder and sentenced to death. At his trial, petitioner admitted participating in the crime but claimed that his companion did the actual killing. In his summation to the jury, petitioner’s counsel conceded that petitioner was guilty of murder in the first degree and asked only that the jury return that verdict “without capital punishment.” Prior to the trial, petitioner’s counsel had requested the prosecution to allow him to examine the companion’s extrajudicial statements. Several of these were shown to him; but one in which the companion admitted the actual killing was withheld by the prosecution and did not come to petitioner’s notice until after he had been tried, convicted and sentenced and after his conviction had been affirmed by the Maryland Court of Appeals. In a post-conviction proceeding, the Maryland Court of Appeals held that suppression of the evidence by the prosecutor denied petitioner due process of law, and it remanded the case for a new trial of the question of punishment, but not the question of guilt, since it was of the opinion that nothing in the suppressed confession “could have reduced [petitioner’s] offense below murder in the first degree.”

Held: Petitioner was not denied a federal constitutional right when his new trial was restricted to the question of punishment; and the judgment is affirmed.
(a) Suppression by the prosecution of evidence favorable to an accused who has requested it violates due process where the evidence is material either to guilt or to punishment, irrespective of the good faith or bad faith of the prosecution.
(b) When the Court of Appeals restricted petitioner’s new trial to the question of punishment, it did not deny him due process or equal protection of the laws under the Fourteenth Amendment, since the suppressed evidence was admissible only on the issue of punishment.
226 Md. 422, 174 A. 2d 167, affirmed.

From the opinion

Opinion of the Court by MR. JUSTICE DOUGLAS, announced by MR. JUSTICE BRENNAN.

Petitioner and a companion, Boblit, were found guilty of murder in the first degree and were sentenced to death, their convictions being affirmed by the Court of Appeals of Maryland. 220 Md. 454, 154 A. 2d 434. Their trials were separate, petitioner being tried first. At his trial Brady took the stand and admitted his participation in the crime, but he claimed that Boblit did the actual killing. And, in his summation to the jury, Brady’s counsel conceded that Brady was guilty of murder in the first degree, asking only that the jury return that verdict “without capital punishment.” Prior to the trial petitioner’s counsel had requested the prosecution to allow him to examine Boblit’s extrajudicial statements. Several of those statements were shown to him; but one dated July 9, 1958, in which Boblit admitted the actual homicide, was withheld by the prosecution and did not come to petitioner’s notice until after he had been tried, convicted, and sentenced, and after his conviction had been affirmed.

Petitioner moved the trial court for a new trial based on the newly discovered evidence that had been suppressed by the prosecution. Petitioner’s appeal from a denial of that motion was dismissed by the Court of Appeals without prejudice to relief under the Maryland [373 U.S. 83, 85] Post Conviction Procedure Act. 222 Md. 442, 160 A. 2d 912. The petition for post-conviction relief was dismissed by the trial court; and on appeal the Court of Appeals held that suppression of the evidence by the prosecution denied petitioner due process of law and remanded the case for a retrial of the question of punishment, not the question of guilt. 226 Md. 422, 174 A 2d 167. The case is here on certiorari,

The crime in question was murder committed in the perpetration of a robbery. Punishment for that crime in Maryland is life imprisonment or death, the jury being empowered to restrict the punishment to life by addition of the words “without capital punishment.” 3 Md. Ann. Code, 1957, Art. 27, 413. In Maryland, by reason of the state constitution, the jury in a criminal case are “the Judges of Law, as well as of fact.” Art. XV, 5. The question presented is whether petitioner was denied a federal right when the Court of Appeals restricted the new trial to the question of punishment.

We agree with the Court of Appeals that suppression of this confession was a violation of the Due Process Clause of the Fourteenth Amendment. The Court of Appeals relied in the main on two decisions from the Third Circuit Court of Appeals – United States ex rel. Almeida v. Baldi, 195 F.2d 815, and United States ex rel. Thompson v. Dye, 221 F.2d 763 – which, we agree, state the correct constitutional rule.

This ruling is an extension of Mooney v. Holohan, 294 U.S. 103, 112 , where the Court ruled on what nondisclosure by a prosecutor violates due process.