Why prosecutors can’t withhold evidence from the defense in a trial
Docket No. 490
Date Argued: Mar 18 - 19, 1963
Date Decided: May 13, 1963
In 1958, Maryland residents Boblit and Brady were both involved in a robbery where an individual was killed. They were convicted of first-degree murder. However, Brady maintained that he did not kill the person; rather, his accomplice, Boblit, killed the person. Once, Boblit had admitted to the murder, but the prosecution withheld this confession which could’ve potentially reduced Brady’s sentence of capital punishment. Brady petitioned the Maryland Court of Appeals stating that his due process under the fourteenth amendment was violated because Boblit’s confession couldn’t be used in court, and the Court of Appeals remanded the case to reconsider the sentencing. Brady then appealed to the Supreme Court of the United States.
(1) Did the prosecution's decision to suppress potentially exculpatory evidence deny Brady due process?
(2) Should the Maryland Court of Appeals have remanded the case on the determinants of guilt as opposed to uniquely the sentencing? (Should the Maryland Court of Appeals have also remanded to have the entire trial redone instead of just the sentencing portion?)
MAJORITY OPINION - (7–2) DECISION FOR BRADY
The Supreme Court recognized that such a suppression does indeed violate someone’s due process rights. The justices held that the “suppression [of evidence]” that’s favorable to the defendant after a request to disclose said evidence, is a due process violation. They also added that regardless of the good faith, or bad faith presented by the prosecution that the end goal is the same—they must disclose evidence that is material towards either the punishment or the trial itself. Justice Douglas mentioned the necessity of the fairness of trials, and that “our system of the administration of justice suffers when any accused is treated unfairly.”
As for the question regarding whether or not the Court of Appeals should’ve remanded on the question of his guilt—the court rightfully denied it. It is important for justices and judges to separate themselves from the notion that they have the mind of a juror. This is further explained in the Court of Appeals opinion where they stated that “[w]e cannot put ourselves in the place of the jury and assume what their views would have been as to whether it did or did not matter whether it was Brady's hands or Boblit's hands that twisted the shirt about the victim's neck.”
PARTIES AND OPINIONS
Side 1 - JOHN BRADY
John Brady is the Petitioner
Claimed that the suppression of evidence at trial violated his due process rights under the Fourteenth Amendment
Claimed that the decision to only remand the case on the question of punishment violated his rights under the Fourteenth Amendment
Side 2 - MARYLAND
Thomas W. Jamison, III (Assistant Attorney General of the State of Maryland) (Respondent’s Advocate)
Maintained that the sentence was appropriate and argued that the claims brought forth have not been violations of his Fourteenth Amendment.
The dissent, in this case, questioned whether or not “the order of the Maryland Court of Appeals granting a new trial, limited to the issue of punishment, violate petitioner's Fourteenth Amendment right to equal protection.” In other words, the dissenting justices argued that there was more fact-finding that needed to take place and that the court shouldn’t rely solely upon the opinion of the lower Maryland Court of Appeals. Justice Harlan summarized this dissent, stating that “further [facts are] consider[ed] in light of the governing constitutional principle.”
This case questions the accountability of the government. Our right to due process (the right that compels the government to adhere to judicial rules and procedures) keeps the government in balance. Rules like the exclusionary rule as established in Mapp v. Ohio, 367 U.S. 643 (1961), ensure that government officials follow proper procedure in order to avoid an entire conviction being thrown out. And as this case necessitates that prosecutors disclose any exculpatory evidence, it’s simply no different.
The Supreme Court of the United States also extended this ruling in future cases as they stated that the prosecution has an “affirmative duty to disclose evidence favorable to a defendant” See Kyles v. Whitley, 514 US 419 (1995). In fact, this case even created its own rule known as the Brady rule, which permits courts to throw out a case if any violation has been found, and this is a very powerful check that ensures the prosecution’s compliance in disclosing any exculpatory evidence. Ultimately, as people are entitled to due process under the Fourteenth Amendment, it’s paramount that the people–and the courts– acknowledge the extent of these constitutional rights.