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Law School Case Brief

Kyles v. Whitley - 514 U.S. 419, 115 S. Ct. 1555 (1995)

Rule:

The prosecution has an affirmative duty to disclose evidence favorable to a defendant. 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.

Facts:

After a defendant's first trial in a Louisiana court ended in a hung jury, he  was tried again, convicted by a jury of first-degree murder, and sentenced to death. Defendant was unsuccessful on direct review and sought state collateral review. Although the accused was ultimately unsuccessful there as well, he was able to present some evidence favorable to him that Louisiana had failed to disclose before or during trial. Eventually, defendant filed a habeas corpus petition in the United States District Court for the Eastern District of Louisiana and included a Brady claim, but the District Court denied the petition. On appeal, the United States Court of Appeals for the Fifth Circuit, in affirming, rejected defendant's Brady claim. The United States Supreme Court granted defendant's petition for certiorari review.

Issue:

Does the failure to disclose evidence favorable to defendant violate his right to due process?

Answer:

Yes.

Conclusion:

The Supreme Court granted certiorari and reversed and ordered a new trial, holding that the net effect of the evidence withheld by the State in this case raised a reasonable probability that its disclosure would have produced a different result.

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