United States ex rel. Thompson v. Dye - 221 F.2d 763 (3d Cir. 1955)

Rule:

The suppression of evidence may be a denial of due process when it is vital evidence, material to the issues of guilt or penalty.

Facts:

Relator-appellant was convicted of first-degree murder and sentenced to death. In relator's second petition for habeas corpus, he sought relief on the grounds that the state withheld and suppressed vital testimony favorable to him at his trial. The district court found the arresting officers had informed the prosecutor that relator was under the influence of alcohol to a quarrelsome degree at the time of his arrest and that the prosecutor failed to communicate this to defense counsel or to the lower court. The district court concluded that the state was not in possession of information or evidence vital to relator's defense that it was obliged to disclose. Relator appealed the judgment.

Issue:

Did the district judge err in holding as a matter of law that the withheld and suppressed evidence was not vital to the defense of the accused?

Answer:

Yes.

Conclusion:

On appeal, the Court noted that the suppression of evidence may be a denial of due process when it was vital evidence, material to the issues of guilt or penalty. In this case, the Court found that there was evidence of the degree of relator's drunken state at the time of the killing. The Court held that because the result of presenting the evidence could have been a finding of second-degree murder or a lower sentence, it should have been presented to the jury. The Court vacated the judgment and remanded the case for an issuance of the writ for habeas corpus.