Brady v. Maryland
Following is the case brief for Brady v. Maryland, United States Supreme Court, (1963)
Case Summary of Brady v. Maryland:
- Brady was convicted of murder and sentenced to death after the prosecution withheld a statement by Boblit in which Boblit confessed to the killing.
- Brady then appealed to the court of appeals claiming that suppressing the statement violated his Constitutional right to Due Process.
- The court held the prosecution’s suppression of the statement was unconstitutional.
- The Supreme Court affirmed, stating that due process requires the prosecution upon request, to turn over evidence that relates to the defendant’s guilt or innocence even if such evidence is favorable to the defense.
Brady v. Maryland Case Brief
Statement of the Facts:
Both Brady and Boblit were suspected of murder. Prior to trial, Brady’s attorney asked to review Boblit’s statements. The Prosecutor kept the statement from Brady, in which Boblit admitted to the actual killing. Brady confessed to his involvement in the crime, but claimed no role in the actual murder. The court found Brady guilty of the murder and sentenced him to death. Brady learned of the suppression of Boblit’s statement after sentencing and appealed.
The court of appeals held the prosecutor improperly suppressed the statement in violation of Due Process.
Rule of Law or Legal Principle Applied:
The Due Process Clause requires the prosecution to turn over evidence relating to a defendant’s guilt, innocence or sentencing upon request, even if it is favorable to the defense.
Issue and Holding:
Whether the prosecution must turn over evidence favorable to the defense under the Due Process Clause? Yes.
The Court affirmed the judgment of the court of appeals.
If the evidence relates to the defendant’s guilt, innocence or sentencing, the Due Process clause requires the prosecution to turn over evidence that is favorable to the defense. In both Mooney v. Holohan, 294 U.S. 103 (1935), and Napue v. Illinois, 360 U.S. 264 (1959), the Court held that prosecutors may not present false testimony or allow false testimony to go uncorrected. The present case builds on that precedent.
Withholding favorable evidence material to culpability or sentencing after a request by the defense equates to a denial of Due Process. The purpose of this rule is to safeguard the accused’s right to a fair trial and finding a violation is in no way contingent upon whether the prosecutor acted in good or bad faith. A fair process serves the good of the people not just merely punishing the guilty.
Concurring and Dissenting opinion:
Dissenting (Harlan joined by Black):
The dissenters do not disagree with the overall outcome so much as the procedure. They held “this case presents only a single federal question: did the order of the Maryland Court of Appeals granting a new trial, limited to the issue of punishment, violate petitioner’s Fourteenth Amendment right to equal protection?”
An affirmative answer would be required if the Boblit statement would have been admissible on the issue of guilt at the trial court level. The appropriate direction would be to vacate the judgment of the Maryland Court of Appeals and remand the case to that court for further consideration in light of governing constitutional principle.
Brady v. Maryland as a landmark case is where we get the present day “Brady Rule” from. The rule requires the prosecution to disclose any material, exculpatory evidence in the government’s possession to the defense, upon the defense’s request.