Law School Case Brief
Brady v. Maryland - 373 U.S. 83, 83 S. Ct. 1194 (1963)
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.
In separate trials in a Maryland state court, where the jury was the judge of both the law and the facts but the court passed on the admissibility of the evidence, petitioner Brady and a companion, Boblit, were convicted of first-degree murder and sentenced to death. At his trial, Brady admitted participating in the crime but claimed that Boblit did the actual killing. In his summation to the jury, Brady's counsel conceded that Brady was guilty of murder in the first degree and asked only that the jury return that verdict "without capital punishment." Prior to the trial, Brady's counsel had requested the prosecution to allow him to examine Boblit’s extrajudicial statements. Several of these were shown to him. However, one in which Boblit admitted to the actual killing was withheld by the prosecution, and it did not come to Brady's notice until after he had been tried, convicted and sentenced and after his conviction had been affirmed by the Court of Appeals of Maryland. In a post-conviction proceeding, the appellate court held that suppression of the evidence by the prosecutor denied Brady due process of law, and it remanded the case for a new trial of the question of punishment, but not the question of guilt, since it was of the opinion that nothing in the suppressed confession could have reduced Brady's offense below murder in the first degree. Brady was granted a writ of certiorari.
Did the suppression of evidence by the State violate Brady's rights under the Due Process Clause, U.S. Const. amend. XIV?
The Supreme Court of the United States held that suppression of evidence favorable to an accused upon request violated the Due Process Clause, U.S. Const. amend. XIV, where the evidence was material to guilt or punishment, regardless of the State's good or bad faith. The suppression of evidence violated Brady's due process rights and required a retrial on the sentence. The Court further ruled that when the state appellate court restricted Brady's new trial to the question of punishment, it did not deny him due process or equal protection of the laws under the Fourteenth Amendment, since the suppressed evidence was admissible only on the issue of punishment.
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