Is The State Obligated To Preserve And Share Evidence That Is Favorable To The Defendant?
Sometimes the black letter law passed by the legislature is unclear. The legislature can’t anticipate every possible fact scenario when they pass a law, so it lay to the courts to interpret the law and give guidance to what it means. This interpretation is called case law. When the court decides a certain meeting to the law it essentially answers a legal question. Lawyers and other courts then can rely on that ruling when they have a similar issue in their case. The following case answers the question above.
Brady v. Maryland, 373 U.S. 83 (1963).
This case answers the following question:
Is the State obligated to preserve and share exculpatory evidence that is favorable to the accused?
The issue in this case is whether suppression of evidence by the prosecution was a violation of the Due Process Clause of the fourteenth amendment. Suppression by the prosecution of evidence favorable to an accused upon request violates due process where the evidence is material either to guilty or to punishment, irrespective of the good faith or bad faith of the prosecution.
The crime in this case was murder committed in the perpetration of a robbery, with a punishment of either life imprisonment or death. Brady and a partner, Boblit, were both found guilty of murder and sentenced to death. Brady’s trial was first, and when he took the stand at trial, he admitted to his participation in the crime, but he claimed that Boblit did the actual killing. Brady’s counsel admitted that Brady was guilty of murder, but he asked the jury to return a verdict of guilty “without capital punishment.” Before the trial had begun, Brady’s counsel had asked the prosecution to see Boblit’s statements. Several of the statements were given to counsel, except one where Boblit admitted the actual homicide. Prosecution withheld that statement, and Brady was not aware of its existence until after he had been convicted and sentenced. Brady was found guilty of murder in the first degree and sentenced to death. The Court of Appeals found that the confession would have no bearing on the guilt of Brady, even though the suppression of the evidence by the prosecutor was a violation of Brady’s due process of law. For this reason, the Court of Appeals of Maryland affirmed the conviction but remanded on the issue of sentencing.
Suppression by the prosecution of evidence favorable to an accused upon request violates due process where the evidence is material either to guilty or to punishment, irrespective of the good faith or bad faith of the prosecution. A prosecution that withholds evidence on demand of an accused which, if made available, would tend to exculpate him or reduce the penalty helps shape a trial that bears heavily on the defendant. A situation like that makes the prosecutor a puppeteer in the proceeding, the exact opposite of a fair trial and justice.
Since it is possible that the jury may have attached some significance to the withheld document, it is then also possible that the jury would have made a different decision when considering the punishment of Brady. However, the information contained in the suppressed evidence was not significant enough that it would have reduced the charge below murder in the first degree. Therefore, the decision of the Court of Appeals of Maryland was affirmed. The prosecution’s suppression of evidence violated the Due Process Clause of the fourteenth amendment.