United States v. Williams

United States Supreme Court
504 U.S. 36 (1992)

ELI5:

Rule of Law:

A district court may not dismiss an otherwise valid indictment on the basis that the government failed to present substantial exculpatory evidence to the grand jury. The federal courts' supervisory power does not extend to prescribing rules of procedure for the grand jury.

Facts:

John H. Williams, Jr., an investor in Tulsa, Oklahoma, sought loans from several federally insured banks between 1984 and 1985.
To influence the banks' decisions, Williams provided them with financial documents, including a 'Market Value Balance Sheet' and a 'Statement of Projected Income and Expense'.
The balance sheet listed approximately $6 million in notes receivable from venture capital companies as 'current assets,' which the government alleged was misleading as the companies could not pay them in the short term.
The income statement showed interest income from these notes, which the government alleged was misleading because Williams himself funded the interest payments through his own loans to the companies.
Williams possessed other financial records, such as general ledgers and tax returns, which he claimed were consistent with his financial statements and would have negated any intent to mislead the banks.
The prosecutor in possession of these potentially exculpatory records did not present them to the grand jury.

Procedural Posture:

A federal grand jury indicted John H. Williams, Jr. on seven counts of making false statements to a federally insured financial institution.
Williams moved in the U.S. District Court to dismiss the indictment, arguing the government failed to present substantial exculpatory evidence to the grand jury as required by Tenth Circuit precedent.
The District Court granted the motion and dismissed the indictment without prejudice.
The United States (appellant) appealed the dismissal to the U.S. Court of Appeals for the Tenth Circuit.
The Court of Appeals affirmed the District Court's dismissal, holding it was not an abuse of discretion.
The United States (petitioner) petitioned the U.S. Supreme Court for a writ of certiorari, which was granted.

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Issue:

Does the federal judiciary's supervisory power permit a court to dismiss an otherwise valid indictment on the grounds that the prosecutor failed to present substantial exculpatory evidence to the grand jury?

Opinions:

Majority - Justice Scalia

No, the federal judiciary's supervisory power does not permit a court to dismiss an indictment for the prosecutor's failure to present substantial exculpatory evidence to the grand jury. The grand jury is an institution separate from the courts, and courts do not have the authority to prescribe its procedures. Historically, the grand jury's function is purely accusatory, not adjudicatory; it sits to determine if there is an adequate basis for a charge, not to determine guilt or innocence. Imposing a duty to present exculpatory evidence would fundamentally alter the grand jury's role by transforming it into an adjudicatory body, which is contrary to its historical function. Furthermore, precedent like Costello v. United States prohibits challenging an indictment based on the sufficiency or competency of the evidence, and allowing a challenge based on withheld exculpatory evidence would create an impermissible end-run around that rule.

Dissenting - Justice Stevens

Yes, a court should be able to dismiss an indictment under these circumstances. The grand jury is not a completely autonomous body but is an 'appendage of the court' and subject to its supervision to ensure fundamental fairness. The prosecutor has a heightened duty to act impartially in the secret, non-adversarial grand jury setting, and this duty includes refraining from improper methods calculated to produce a wrongful indictment. Allowing prosecutors to intentionally mislead the grand jury by withholding clear, substantial evidence that negates guilt subverts the grand jury's essential role as a 'protector of citizens against arbitrary and oppressive governmental action.' The Court's supervisory power is necessary and appropriate to redress such prejudicial prosecutorial misconduct that distorts the grand jury's legitimate function.

Analysis:

This decision sharply curtails the scope of the federal judiciary's supervisory power over grand jury proceedings, firmly establishing that this power does not authorize courts to create procedural rules for prosecutors. It reinforces the grand jury's independence from the judicial branch and solidifies its role as a one-sided, accusatory body rather than a forum for mini-trials. By rejecting a duty to disclose exculpatory evidence, the Court significantly limited the grounds on which a defendant can challenge a facially valid indictment, directing such challenges toward violations of specific constitutional provisions, statutes, or procedural rules, rather than general principles of fairness.

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