Brady v. Maryland
373 U.S. 83, 10 L. Ed. 2d 215 (1963)
Rule of Law:
The prosecution's suppression of evidence favorable to an accused upon request violates the Due Process Clause of the Fourteenth Amendment where the evidence is material to either guilt or punishment, irrespective of the good faith or bad faith of the prosecution.
Facts:
- John Brady and his companion, Charles Boblit, were prosecuted for a murder committed during the course of a robbery.
- At his trial, Brady admitted to participating in the crime but claimed that Boblit had performed the actual killing.
- Prior to trial, Brady's counsel requested that the prosecution allow him to examine all of Boblit's extrajudicial statements.
- The prosecution turned over several of Boblit's statements to the defense.
- The prosecution withheld one specific statement in which Boblit admitted that he, not Brady, had committed the actual homicide.
- Brady did not learn of this suppressed statement until after he was tried, convicted of first-degree murder, and sentenced to death.
Procedural Posture:
- John Brady was tried in a Maryland state trial court, convicted of first-degree murder, and sentenced to death.
- The Maryland Court of Appeals, the state's highest court, affirmed the conviction and sentence.
- Brady discovered the withheld evidence and moved the trial court for a new trial; the motion was denied.
- Brady then sought post-conviction relief, which was dismissed by the trial court.
- On appeal from the dismissal of his post-conviction petition, the Maryland Court of Appeals held that the prosecution's suppression of evidence denied Brady due process.
- The Maryland Court of Appeals remanded the case for a new trial limited only to the question of punishment, not guilt.
- Brady (the petitioner) successfully petitioned the U.S. Supreme Court for a writ of certiorari to review the limited nature of the remedy.
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Issue:
Does the prosecution's suppression of evidence favorable to an accused upon request violate the Due Process Clause of the Fourteenth Amendment, where the evidence is material to either guilt or punishment?
Opinions:
Majority - Mr. Justice Douglas
Yes. The suppression by the prosecution of evidence favorable to an accused upon request 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. This principle is not intended to punish prosecutors but to ensure the accused receives a fair trial. The court affirmed the Maryland Court of Appeals' decision to remand for a new trial on the question of punishment only, reasoning that the suppressed confession, under Maryland law as interpreted by its highest court, would not have been admissible to negate Brady's guilt but could have persuaded the jury to impose a life sentence instead of death.
Concurring - Mr. Justice White
This opinion concurs only in the judgment, arguing that the Court should not have reached the broad due process question. Justice White contended that the majority's due process discussion was advisory because the state court's ruling may have rested on the Maryland Constitution, and the state had not challenged the finding of a due process violation. He cautioned against casting a broad rule of criminal discovery in constitutional form, preferring to leave such tasks to legislative processes, but agreed with the Court's ultimate disposition of the petitioner's equal protection argument regarding the limited retrial.
Dissenting - Mr. Justice Harlan
The dissent argues that the majority incorrectly interpreted Maryland law regarding the admissibility of the suppressed statement. Justice Harlan found the Maryland Court of Appeals' opinion ambiguous as to whether Boblit's confession would have been admissible on the issue of Brady's guilt. Citing the State's own admission during oral argument that the statement would have been admissible for guilt, the dissent concludes that the proper course would be to vacate the judgment and remand to the state court for clarification on this critical issue of state law before resolving the federal constitutional question.
Analysis:
Brady v. Maryland established a landmark constitutional rule that fundamentally altered criminal discovery and prosecutorial ethics. The 'Brady rule' imposes an affirmative duty on prosecutors to disclose exculpatory evidence to the defense, shifting the focus from prosecutorial misconduct (as in Mooney v. Holohan) to the fairness of the trial itself. This decision created a crucial due process protection for defendants by ensuring they have access to information that could prove their innocence or mitigate their punishment. The case has had a profound and lasting impact, forming the basis for countless subsequent decisions defining the scope of material, favorable evidence that must be disclosed.
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