Law School Case Brief
Kyles v. Whitley - 514 U.S. 419, 115 S. Ct. 1555 (1995)
Under one factor of the Bagley test, although the constitutional duty to disclose evidence is triggered by the potential impact of favorable but undisclosed evidence, a showing of materiality does not require demonstration by a preponderance that disclosure of the suppressed evidence would have resulted ultimately in the defendant's acquittal, whether based on the presence of reasonable doubt or acceptance of an explanation for the crime that does not inculpate the defendant. The touchstone of materiality is a "reasonable probability" of a different result, and the adjective is important. The question is not whether the defendant would more likely than not have received a different verdict with the evidence, but whether in its absence he received a fair trial, understood as a trial resulting in a verdict worthy of confidence. A "reasonable probability" of a different result is accordingly shown when the government's evidentiary suppression undermines confidence in the outcome of the trial.
Defendant was convicted of first-degree murder. He appealed, claiming that the State knew of evidence favorable to him before and during trial that it failed to disclose. The state supreme court remanded the case for an evidentiary hearing on defendant's claims of newly discovered evidence. The trial court, after review, denied relief. The state supreme court denied defendant's application for discretionary review. Defendant then filed a petition for habeas corpus in the federal district court, which denied the petition. The court of appeals affirmed by a divided vote. Defendant then petitioned for certiorari review by the United States Supreme Court.
Was a defendant entitled to a new trial because of the prosecution's failure to comply with the due process obligation to disclose favorable material evidence?
The Supreme Court granted certiorari, reversed, and ordered a new trial, holding that the net effect of the evidence withheld by the State raised a reasonable probability that its disclosure would have produced a different result. The net effect of the evidence withheld by the state raised a reasonable probability that the evidence's disclosure to competent counsel would have produced a different result, as, among other factors, (1) contrary to the incorrect standard for materiality that the Court of Appeals may have used, the state's disclosure obligation turns on the cumulative effect of all such suppressed evidence; and (2) a prosecutor remains responsible for gauging that effect regardless of any failure by the police to bring favorable evidence to the prosecutor's attention.
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