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Brady v. Maryland

Supreme Court of the United States · 1963 · Criminal Procedure

Criminal Proceduredue processprosecutorial disclosureexculpatory evidenceBrady materialDue Process ClauseFourteenth Amendmentprosecutorial suppression

Facts

Brady and his companion Boblit were separately tried for first-degree murder committed during a robbery, and Brady was tried first. At trial, Brady admitted participating in the crime but claimed Boblit did the actual killing, and his counsel conceded guilt of first-degree murder while asking the jury to return a verdict without capital punishment. Before trial, Brady's counsel requested Boblit's extrajudicial statements; the prosecution disclosed several but withheld a July 9, 1958 statement in which Boblit admitted the actual homicide. Brady learned of that statement only after trial, conviction, sentencing, and affirmance of his conviction.

Issue

Whether the prosecution's suppression, upon request, of Boblit's confession violated due process, and if so, whether the Maryland Court of Appeals denied Brady a federal right by limiting the new trial to punishment rather than guilt. More specifically, the question was whether Brady was entitled to a retrial on guilt as well as punishment.

Rule

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. But where the suppressed evidence is not admissible on the issue of guilt and bears only on punishment, due process does not require a new trial on guilt.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

In Phoenix, Noah Benton was tried for armed robbery and murder arising from a convenience-store holdup. Before trial, his lawyer asked the prosecutor for all statements made by Noah's alleged accomplice, and the prosecutor withheld one statement in which the accomplice said Noah never entered the store and did not know anyone planned a killing.

If the withheld statement would have been admissible and would have tended to exculpate Noah on the murder charge, which is the best answer?

Explanation. The governing rule is that suppression by the prosecution of evidence favorable to the accused upon request violates due process when the evidence is material to guilt or punishment, regardless of the prosecutor's good faith or bad faith. A statement that tends to exculpate Noah on guilt falls within that rule.