Summary of Brady v. Maryland
Citation: 373 U.S. 83 (1963)
Relevant Facts: Petitioner Brady was convicted in a Maryland Court of murder in the first degree. At trial, he admitted his complicity in the planning and commission of the crime, but denied having personally committed the killing that was instead perpetrated by his companion. Defense counsel admitted his client’s guilt at trial, explaining to the jury that they should find him guilty but not impose the death penalty due to his lesser culpability. Brady’s attorney, prior to trial, requested access to all of the accomplice’s statements to police, most of which were provided. However, one statement was withheld. The substance of that statement showed that the accomplice admitted to actually committing the murder. Defense Counsel, in post-conviction proceedings, raised the issue and demanded a new trial. The Maryland Court of Appeals agreed that the withholding of evidence violated due process, and remanded the case, but ordered new proceedings as to sentence only and not as to guilt.
Issues: Does withholding of evidence favorable to a defendant violate that defendant’s due process rights? Under the circumstances of this case, did limitations on new proceedings as to punishment only violate defendant’s due process rights?
Holding: Yes, withholding evidence favorable to the defendant as to either guilt or punishment violates a defendant’s due process rights irrespective of the intentions of prosecutors. No, the defendant’s due process rights were not violated when his new trial was restricted to punishment only, as the evidence in question only pertained to his relative culpability and appropriate punishment, not his underlying guilt.
Reasoning: The Court, in an opinion by Justice Douglas, discussed past cases concerning misconduct sufficient to violate due process. In those cases, the Court held that offering perjured testimony or failure to correct inaccurate testimony deprived a defendant of due process. Here the Court extended that line of reasoning, concluding that suppression of evidence alone is sufficient to violate due process, where such evidence is material to either guilt or punishment, without regard to the motivations behind the suppression. According to the Court, due process requirements not only constrain the behavior of prosecutors, but ensure that the process itself is fair such that the result is just. Next, the Court considered the appropriateness of the remedy, to wit, the demand for a new trial but the limitation of that trial to the sentencing phase alone. Justice Douglas explained that in Maryland, juries serve not only as finders of fact but also labor to judge the appropriate law. However, he found that distinction from other jurisdictions did not aide the petitioner’s claims here. Relying heavily on the decision of the Maryland Court of Appeals, the Court accepted their determination that nothing in the suppressed statement could have lessened the defendant’s guilt or served to sufficiently alleviate him of responsibility for any crime other than that of murder in the first degree. While the evidence was relevant to determining a fair punishment, the Court concluded that the jury would have had no basis to alter their assessment of his guilt or the crime of which he was convicted. Accordingly, the Court affirmed the order below, concluded that the remedy adopted was consistent with due process.
Dissent: Justice White filed a separate opinion, arguing that the Court should not have reached the due process issue as it was unclear whether the decision below rested on state or federal grounds. He also suggested that the rule adopted here went too far, preferring instead to leave crafting of criminal discovery rules to legislative bodies. Justice Harlan, joined by Justice Black, dissented, preferring to dispose of the case on equal protection grounds, and arguing that the relevant inquiry was whether the suppressed statement pertained to guilt. Justice Harlan argued that nothing in the record decisively suggested that the statement would not have been relevant during the guilt phase of trial. Furthermore, he concluded that given the failure of the Court of Appeals to adequately address the equal protection argument in this case, the Court should have declined to proceed and in any event should have avoided the sweeping due process rule adopted.
Conclusion: Suppression of evidence alone is sufficient to violate due process, but under the circumstances of this particular case and the unusual nature of Maryland trials and the duties imposed upon their juries, a new trial was unnecessary here as to the guilt phase.