Application and Analysis of Brady v. Maryland

Application and Analysis of Brady v. Maryland
After reading Brady v. Maryland (see below) answer the following in no less than 100 words:
Matthew works as a paralegal for the prosecutor’s office. While organizing a file in preparation for trial, he comes across the name and telephone number of a witness who testified the perpetrator of the crime as someone other than the defendant named in the case. It does not appear from the file that the defense attorney was advised of this fact. Matthew brings this to the attention of the attorney handling the case, who tells him to forget about it. After all, it is not the prosecutor’s job to defend anyone accused of a crime. What should Matthew do?

 

U.S. Supreme Court

BRADY v. MARYLAND, 373 U.S. 83 (1963)
373 U.S. 83
BRADY v. MARYLAND.
CERTIORARI TO THE COURT OF APPEALS OF MARYLAND.
No. 490.
Argued March 18-19, 1963.
Decided May 13, 1963

Opinion of the Court by MR. JUSTICE DOUGLAS, announced by MR. JUSTICE BRENNAN.

Petitioner and a companion, Boblit, were found guilty of murder in the first degree and were sentenced to death, their convictions being affirmed by the Court of Appeals of Maryland. 220 Md. 454, 154 A. 2d 434. Their trials were separate, petitioner being tried first. At his trial Brady took the stand and admitted his participation in the crime, but he claimed that Boblit did the actual killing. And, in his summation to the jury, Brady’s counsel conceded that Brady was guilty of murder in the first degree, asking only that the jury return that verdict “without capital punishment.” Prior to the trial petitioner’s counsel had requested the prosecution to allow him to examine Boblit’s extrajudicial statements. Several of those statements were shown to him; but one dated July 9, 1958, in which Boblit admitted the actual homicide, was withheld by the prosecution and did not come to petitioner’s notice until after he had been tried, convicted, and sentenced, and after his conviction had been affirmed.

Petitioner moved the trial court for a new trial based on the newly discovered evidence that had been suppressed by the prosecution. Petitioner’s appeal from a denial of that motion was dismissed by the Court of Appeals without prejudice to relief under the Maryland [373 U.S. 83, 85] Post Conviction Procedure Act. 222 Md. 442, 160 A. 2d 912. The petition for post-conviction relief was dismissed by the trial court; and on appeal the Court of Appeals held that suppression of the evidence by the prosecution denied petitioner due process of law and remanded the case for a retrial of the question of punishment, not the question of guilt. 226 Md. 422, 174 A 2d 167. The case is here on certiorari, 371 U.S. 812 . 1

The crime in question was murder committed in the perpetration of a robbery. Punishment for that crime in Maryland is life imprisonment or death, the jury being empowered to restrict the punishment to life by addition of the words “without capital punishment.” 3 Md. Ann. Code, 1957, Art. 27, 413. In Maryland, by reason of the state constitution, the jury in a criminal case are “the Judges of Law, as well as of fact.” Art. XV, 5. The question presented is whether petitioner was denied a federal right when the Court of Appeals restricted the new trial to the question of punishment. [373 U.S. 83, 86]

We agree with the Court of Appeals that suppression of this confession was a violation of the Due Process Clause of the Fourteenth Amendment. The Court of Appeals relied in the main on two decisions from the Third Circuit Court of Appeals – United States ex rel. Almeida v. Baldi, 195 F.2d 815, and United States ex rel. Thompson v. Dye, 221 F.2d 763 – which, we agree, state the correct constitutional rule.

This ruling is an extension of Mooney v. Holohan, 294 U.S. 103, 112 , where the Court ruled on what nondisclosure by a prosecutor violates due process:
“It is a requirement that cannot be deemed to be satisfied by mere notice and hearing if a State has contrived a conviction through the pretense of a trial which in truth is but used as a means of depriving a defendant of liberty through a deliberate deception of court and jury by the presentation of testimony known to be perjured. Such a contrivance by a State to procure the conviction and imprisonment of a defendant is as inconsistent with the rudimentary demands of justice as is the obtaining of a like result by intimidation.”

In Pyle v. Kansas, 317 U.S. 213, 215 -216, we phrased the rule in broader terms:

“Petitioner’s papers are inexpertly drawn, but they do set forth allegations that his imprisonment resulted from perjured testimony, knowingly used by the State authorities to obtain his conviction, and from the deliberate suppression by those same authorities of evidence favorable to him. These allegations sufficiently charge a deprivation of rights guaranteed by the Federal Constitution, and, if proven, would entitle petitioner to release from his present custody. Mooney v. Holohan, 294 U.S. 103 .” [373 U.S. 83, 87]

The Third Circuit in the Baldi case construed that statement in Pyle v. Kansas to mean that the “suppression of evidence favorable” to the accused was itself sufficient to amount to a denial of due process. 195 F.2d, at 820. In Napue v. Illinois, 360 U.S. 264, 269 , we extended the test formulated in Mooney v. Holohan when we said: “The same result obtains when the State, although not soliciting false evidence, allows it to go uncorrected when it appears.” And see Alcorta v. Texas, 355 U.S. 28 ; Wilde v. Wyoming, 362 U.S. 607 . Cf. Durley v. Mayo, 351 U.S. 277, 285 (dissenting opinion).
We now hold that the suppression by the prosecution of evidence favorable to an accused upon request violates due process where the evidence is material either to guilt or to punishment, irrespective of the good faith or bad faith of the prosecution.

The principle of Mooney v. Holohan is not punishment of society for misdeeds of a prosecutor but avoidance of an unfair trial to the accused. Society wins not only when the guilty are convicted but when criminal trials are fair; our system of the administration of justice suffers when any accused is treated unfairly. An inscription on the walls of the Department of Justice states the proposition candidly for the federal domain: “The United States wins its point whenever justice is done its citizens in the courts.” 2 A prosecution that withholds evidence on demand of an accused which, if made available, [373 U.S. 83, 88] would tend to exculpate him or reduce the penalty helps shape a trial that bears heavily on the defendant. That casts the prosecutor in the role of an architect of a proceeding that does not comport with standards of justice, even though, as in the present case, his action is not “the result of guile,” to use the words of the Court of Appeals. 226 Md., at 427, 174 A. 2d, at 169.

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