Law School Case Brief
United States v. Williams - 504 U.S. 36, 112 S. Ct. 1735 (1992)
The grand jury sits not to determine guilt or innocence, but to assess whether there is adequate basis for bringing a criminal charge. It is the grand jury's function not to inquire upon what foundation the charge may be denied, or otherwise to try the suspect's defenses, but only to examine upon what foundation the charge is made by the prosecutor.
Respondent Williams was accused of and eventually indicted but the federal grand jury for making false statements to a bank. The respondent, claimed that the prosecutor did not present exculpatory evidence, thus, respondent sought to overturn his indictment. The indictment was overturned by the District Court and appeals followed.
Can a district court dismiss a valid indictment because of the Government’s failure to disclose exculpatory evidence to the grand jury?
The Court reversed the dismissal holding that the rule requiring disclosure to the grand jury of "substantial exculpatory evidence" was not supported by the trial court's "supervisory power," because the grand jury was an institution over whose functioning the courts did not preside. The rule was inconsistent with the traditional function of the grand jury, which was to determine whether enough evidence existed to prosecute, not to allow the accused to put on a defense. The Court refused to convert a non-existent duty of the grand jury itself into an obligation of the prosecutor.
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