Law School Case Brief
United States v. Bagley - 473 U.S. 667, 105 S. Ct. 3375 (1985)
Consistent with the U.S. Supreme Court's overriding concern with the justice of the finding of guilt, in a case involving Brady materials, a constitutional error occurs, and the conviction must be reversed, only if the evidence is material in the sense that its suppression undermines confidence in the outcome of the trial.
Defendant Hughes Anderson Bagley was convicted of various narcotics violations in a bench trial in a federal district Court. Defendant moved to vacate his sentence, contending that his due process rights under the rule of Brady v Maryland. which required prosecutors to disclose material evidence favorable to an accused. Defendant argued that the prosecution had failed to disclose before trial that federal agents had contracted to pay the prosecution's only witnesses for information and testimony against defendant, despite a defense motion for disclosure of any inducements made to prosecution witnesses in exchange for their testimony. The district court denied the motion, finding beyond a reasonable doubt that a disclosure of these contracts before trial would not have affected its verdict because the witnesses' testimony had primarily related to other charges of which defendant had been acquitted and defense counsel had not attempted to discredit their relatively brief testimony concerning the narcotics charges. The United States Court of Appeals for the Ninth Circuit reversed, holding that the prosecution's failure to disclose requested information that the defense could have used to conduct an effective cross-examination impaired defendant's right to confront adverse witnesses, and therefore, required an automatic reversal of his conviction. The government sought further review in the United States Supreme Court.
Did the prosecution’s failure to disclose information, which the defense could have used to conduct an effective cross-examination, impair a defendant’s right to confront adverse witnesses?
Yes, if the evidence is material.
The United States Supreme Court reversed the decision of the appellate court, and remanded the case for further proceedings. The Court held that prosecutor’s failure to assist a defendant by disclosing evidence that might be helpful in conducting cross-examination was a constitutional error only if the evidence was material in the sense that its suppression might have affected the outcome of the trial. According to the Court, the non-disclosed evidence at issue was material only if there was a reasonable probability that, had the evidence been disclosed to the defense, the result of the proceeding would have been different.
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