Re: Main Issues Involved in Key United States Supreme Court Cases
Since 1963, the United States Supreme Court has taken an expansive view of Due Process as it applies to criminal defendants. A number of important Supreme Court decisions have addressed the scope of a Prosecutor’s constitutional duties in light of the Due Process Clause of the Fourteenth Amendment. Although the Prosecutor stands in an adversarial position to the criminal defendant, the Prosecutor is sometimes required to disclose various forms of evidence that may be favorable to the defendant. These cases touch upon the delicate balance between a vigorous Prosecution and the defendant’s right to a fair trial consistent with Due Process. This memo provides a general overview of the key Supreme Court cases that provide the framework for Prosecutorial duties and responsibilities under the Due Process Clause.
Brady v. Maryland, 373 U.S. 83 (1963)
Brady and a companion were found guilty of murder in a Maryland Court. Both defendants were sentenced to death, and the Maryland Court of Appeals upheld the convictions. Brady admitted that he was involved in the planning of the murder, but that his companion committed the actual killing. Brady’s defense counsel admitted that Brady was guilty, but the jury should not impose the death penalty because he was not the actual killer. Before the trial, Brady’s counsel had requested that the prosecution allow him to examine the companion’s extrajudicial statements, but these requests were refused. The statement that the Prosecution withheld revealed that Brady’s companion was the actual killer (Gesme, 2009). Brady’s defense did not learn of this withholding until after Brady had been tried, convicted, and sentenced to death. Brady filed a petition for post conviction relief, which was denied by the trial court. The Maryland Court of Appeals, however, held that the prosecution wrongfully withheld evidence from the defense and this constituted a denial of Due Process.
The issue for the Supreme Court was whether the Prosecution’s withholding of the companion’s exculpatory statement violated Brady’s right to due process under the Fourteenth Amendment. The companion’s statement was “material either to guilt or punishment” (Brady v. Maryland, 1963, p. 87). The Court ultimately affirmed the Maryland Court of Appeals opinion, held that the Prosecution had violated Brady’s due process rights by failing to disclose the companion’s confession to the defense.
United States v. Agurs, 427 U.S. 97 (1976)
This case concerned a defendant who was convicted of second-degree murder. The defendant and the victim were sharing a hotel room. A hotel employee heard screams and found the defendant and the victim struggling for possession of a knife. The victim sustained several knife wounds and died from these wounds. The defendant did not have any knife wounds. At trial, the defendant’s counsel argued that the murder was in self defense. After the defendant was convicted for second-degree murder, the defense discovered that the prosecution had failed to disclose that the victim had a prior criminal record. The defense argued that the Prosecutor had a duty to disclose this information to the defense. The defense thereby filed a motion for a new trial in light of the undisclosed criminal record of the victim. The District Court denied the motion, but the Court of Appeals reversed, concluding that the evidence of the victim’s criminal record was material and that the jury might have rendered a different verdict against the defendant had this evidence been disclosed.
The Supreme Court held that the prosecutor’s failure to divulge the victim’s criminal record did not deprive the defendant of a fair trial guaranteed by the Due Process Clause. The Court distinguished Brady from this case, and held that the three types of circumstances that require disclosure were not present in the defendant’s situation. Furthermore, the Court held that Due Process does not require the Prosecutor to turn over any and all evidence that could possibly influence a jury decision, just evidence that is sufficiently significant to create reasonable doubt of the defendant’s guilt.
Giglio v. United States, 405 U.S. 150 (1972)
Unlike the Brady and Agur cases, this case does not concern a Prosecutor’s failure to disclose certain exculpatory evidence to the defense. Instead, this case addresses a Prosecutor’s constitutional duty to inform a jury about material evidence regarding witnesses. The Prosecutor struck a deal with a witness who testified against the defendant at trial. The Prosecution promised the witness that no charges would be brought against the witness if he testified against the defendant. At the defendant’s trial, the Prosecution never told the jury about this deal. The defendant was subsequently found guilty and sentenced to prison. The Supreme Court granted certiorari to evaluate whether this failure to disclose such evidence constituted a violation of Due Process in light of the Brady decision.
The Brady holding served as a guidepost for the Supreme Court’s analysis in this case. In Brady, the Court had that a Prosecutor’s failure to divulge material evidence is a denial of due process and requires a new trial. In this case, the Prosecutor’s failure to inform the jury about the deal the witness has struck with the government was material evidence and should have been disclosed to the jury. The Prosecution’s failure to disclose this evidence was a denial of the defendant’s due process rights and the Court subsequently ordered a new trial.
In summary, these three cases show that while the Prosecution does not need to disclose any and all evidence that may be favorable to the defendant, the Prosecution is under a constitutional duty to disclose evidence that has a material impact on a guilt or innocence. Imposing this duty on the Prosecution is consistent with notions of fundamental fairness and justice. Because the Prosecution stands in a much more advantageous position than the defense, these cases recognize that the Prosecution must abide by certain due process requirements and standards in order to ensure that the defendant receives a fair trial.
References
Brady v. Maryland, 373 U.S. 83 (1963).
Gesme, D., & Wiseman, M. (2009). Brady case in the Supreme Court. Journal of Criminal
Justice, 6(5), 257-259. doi:10.1200/jop.000089.
Giglio v. United States, 405 U.S. 150 (1972)
United States v. Agurs, 427 U.S. 97 (1976)
