Wood v. Bartholomew
1995 U.S. LEXIS 6760, 516 U.S. 1, 133 L. Ed. 2d 1 (1995)
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Rule of Law:
The prosecution's failure to disclose evidence that is itself inadmissible does not violate due process under Brady v. Maryland unless there is a reasonable probability that its disclosure would have led to the discovery of admissible evidence that would have changed the outcome of the trial.
Facts:
- On August 1, 1981, Dwayne Bartholomew robbed a laundromat in Tacoma, Washington, during which the attendant was shot and killed.
- Bartholomew admitted to the robbery and that the fatal shots came from his gun, but claimed his single-action revolver discharged accidentally twice; the central issue at trial was whether the killing was premeditated.
- Bartholomew’s brother, Rodney, and Rodney's girlfriend, Tracy Dormady, testified that Bartholomew had told them he intended to rob the laundromat and 'leave no witnesses.'
- Bartholomew testified that Rodney had assisted in the initial stages of the crime before leaving.
- Prior to trial, the prosecution administered polygraph examinations to both Rodney and Tracy.
- The examiner concluded that Rodney's answers denying his own involvement in the robbery indicated deception.
- The prosecution did not disclose the existence or the results of these polygraph examinations to the defense.
Procedural Posture:
- Dwayne Bartholomew was convicted of aggravated first-degree murder in a Washington state trial court.
- After exhausting state remedies, Bartholomew filed a petition for a writ of habeas corpus in the U.S. District Court for the Western District of Washington.
- The District Court denied the habeas petition, finding the withheld information was not material evidence.
- Bartholomew (appellant) appealed to the U.S. Court of Appeals for the Ninth Circuit.
- The Ninth Circuit Court of Appeals reversed the District Court, concluding the failure to disclose the polygraph results was a material Brady violation.
- The State of Washington, represented by Superintendent Wood (petitioner), petitioned the U.S. Supreme Court for a writ of certiorari.
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Issue:
Does the prosecution's failure to disclose inadmissible polygraph results of a key witness violate a defendant's due process rights under Brady v. Maryland when there is no reasonable probability that disclosure would have led to a different trial outcome?
Opinions:
Majority - Per Curiam
No. The prosecution's failure to disclose inadmissible evidence does not violate Brady unless the information is 'material,' meaning there is a reasonable probability that, had the evidence been disclosed, the result of the proceeding would have been different. Because the polygraph results were inadmissible under Washington state law, they were not 'evidence' and could have had no direct effect on the trial's outcome. The Ninth Circuit's conclusion that disclosure might have led the defense to conduct additional discovery that might have uncovered admissible evidence is 'mere speculation' and does not meet the materiality standard established in United States v. Bagley. The defendant's own trial counsel testified that knowing about the results would not have changed his cross-examination or the case's outcome. Given the overwhelming physical and testimonial evidence against Bartholomew, there is no reasonable probability that disclosure would have resulted in an acquittal.
Dissenting - Justice Stevens, Justice Souter, Justice Ginsburg, and Justice Breyer
These justices dissented from the summary disposition of the case, indicating they believed the case warranted full briefing and oral argument rather than a decision based solely on the petition filings.
Analysis:
This case significantly clarifies the materiality prong of the Brady test, particularly concerning evidence that is not directly admissible at trial. The Court's holding raises the bar for defendants, requiring more than mere speculation that inadmissible information could have led to the discovery of admissible, exculpatory evidence. It establishes that to be 'material,' such information must carry a 'reasonable probability' of altering the trial's outcome, thereby narrowing the scope of the prosecution's disclosure obligations. This decision reinforces the finality of convictions by preventing them from being overturned based on speculative, attenuated claims of prejudice.
