United States v. Agurs
427 U.S. 97 (1976)
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Rule of Law:
When a prosecutor fails to voluntarily disclose exculpatory evidence to the defense in the absence of a specific request, the Due Process Clause is violated only if the omitted evidence is material enough to create a reasonable doubt about the defendant's guilt that did not otherwise exist.
Facts:
- On September 24, 1971, respondent and James Sewell checked into a motel room.
- Sewell was wearing a bowie knife in a sheath and carried another knife in his pocket.
- Approximately 15 minutes after they checked in, motel employees heard the respondent screaming for help.
- The employees forced entry into the room and discovered Sewell on top of the respondent, struggling for possession of the bowie knife as respondent held it.
- The respondent departed the scene before authorities arrived; Sewell was dead on arrival at the hospital from multiple deep stab wounds.
- An autopsy revealed Sewell had defensive wounds on his hands and arms, while a physical examination of the respondent showed no cuts or bruises.
- Sewell had a prior criminal record, including guilty pleas for assault with a deadly weapon and carrying a deadly weapon (both involving knives), which the prosecution did not disclose to the defense.
Procedural Posture:
- The respondent was convicted of second-degree murder in the U.S. District Court.
- After the verdict, defense counsel filed a motion for a new trial, arguing the prosecution failed to disclose the victim's prior criminal record in violation of Brady v. Maryland.
- The District Court denied the motion, holding that the undisclosed evidence was not sufficiently material to warrant a new trial.
- The respondent (as appellant) appealed the conviction and the denial of the new trial motion to the U.S. Court of Appeals for the District of Columbia Circuit.
- The Court of Appeals (with the United States as appellee) reversed the District Court's decision, finding the evidence material and ordering a new trial.
- The United States (as petitioner) successfully petitioned the U.S. Supreme Court for a writ of certiorari to review the Court of Appeals' judgment.
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Issue:
Does a prosecutor's failure to voluntarily disclose a murder victim's prior criminal record to a defendant claiming self-defense violate the Due Process Clause of the Fifth Amendment if the undisclosed evidence, viewed in the context of the entire record, does not create a reasonable doubt as to the defendant's guilt?
Opinions:
Majority - Mr. Justice Stevens
No, the prosecutor's failure to voluntarily disclose the victim's criminal record did not violate the Due Process Clause. A prosecutor's constitutional duty to disclose is not violated unless the omission is of sufficient significance to result in the denial of a fair trial. The proper standard of materiality for undisclosed evidence, when no specific request was made, is whether the evidence creates a reasonable doubt that did not otherwise exist. Here, Sewell’s prior record was largely cumulative of evidence already presented (that he carried two knives) and did not contradict any prosecution evidence. Given the multiple stab wounds suffered by Sewell compared to the respondent's unscathed condition, the trial judge's conclusion that the record did not create a reasonable doubt about her guilt was entirely reasonable.
Dissenting - Mr. Justice Marshall
Yes, the prosecutor's failure to disclose violated the Due Process Clause. The majority's standard of materiality is so narrow that it deprives the prosecutor's duty to volunteer exculpatory evidence of any meaningful content, treating it no differently than newly discovered evidence from a neutral source. The proper standard should be whether there is a significant chance that the withheld evidence, developed by skilled counsel, would have induced a reasonable doubt in the minds of enough jurors to avoid a conviction. The majority’s rule usurps the jury's function by making the judge the final trier of fact regarding the materiality of withheld evidence and creates an incentive for prosecutors to resolve disclosure questions in favor of concealment.
Analysis:
This case establishes a tripartite framework for analyzing the materiality of undisclosed exculpatory evidence under Brady v. Maryland. It distinguishes between cases involving prosecutorial use of perjury, specific defense requests for evidence, and cases with no request or only a general request. By setting a high materiality standard for the third and most common category—that the evidence must create a reasonable doubt—the decision narrowed the scope of the Brady rule. This holding makes it more difficult for defendants to obtain a new trial based on a prosecutor's failure to disclose, shifting the focus from the prosecutor's conduct to the ultimate impact of the evidence on the trial's outcome.
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