Brady v. Maryland
| Brady v. Maryland | |
|---|---|
|
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| Argued March 18–19, 1963 Decided May 13, 1963 |
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| Full case name | Brady v. State of Maryland |
| Citations | 373 U.S. 83 (more)
83 S. Ct. 1194; 10 L. Ed. 2d 215; 1963 U. S. LEXIS 1615
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| Prior history | Certiorari to the Court of Appeals of Maryland |
| Holding | |
| Withholding of evidence violates due process "where the evidence is material either to guilt or to punishment. " | |
| Court membership | |
| Case opinions | |
| Majority | Douglas, joined by Warren, Clark, Brennan, Stewart, Goldberg |
| Concurrence | White |
| Dissent | Harlan, joined by Black |
| Laws applied | |
| U. S. Const. amend. XIV | |
Brady v. Maryland, 373 U.S. 83 (1963) was a landmark United States Supreme Court case that established that the prosecution must turn over all evidence that might exonerate the defendant (exculpatory evidence) to the defense. The prosecution failed to do so for Brady and he was convicted. Brady challenged his conviction, arguing it had been contrary to the Due Process Clause of the Fourteenth Amendment to the United States Constitution.
Maryland prosecuted John Leo Brady and a companion, Donald Boblit, for murder. Brady admitted being involved in the murder, but claimed Boblit had done the actual killing. The prosecution had withheld a written statement by Boblit confessing that he had committed the act of killing by himself. The Maryland Court of Appeals had affirmed the conviction and remanded the case for a retrial only on the question of punishment.
The Supreme Court held that withholding exculpatory evidence violates due process "where the evidence is material either to guilt or to punishment"; and the court determined that under Maryland state law the withheld evidence could not have exculpated the defendant but was material to the level of punishment he would be given. Hence the Maryland Court of Appeals' ruling was affirmed.
A defendant's request for "Brady disclosure" refers to the holding of the Brady case, and the numerous state and federal cases that interpret its requirement that the prosecution disclose material exculpatory evidence to the defense. Exculpatory evidence is “material” if “there is a reasonable probability that his conviction or sentence would have been different had these materials been disclosed.” Brady evidence includes statements of witnesses or physical evidence that conflicts with the prosecution's witnesses, and evidence that could allow the defense to impeach the credibility of a prosecution witness.
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