John Leo Brady and a codefendant, Boblit, were convicted of first-degree murder and sentenced to death. Brady admitted participating in the crime but claimed Boblit committed the actual killing. Before trial, Brady requested Boblit's extrajudicial statements, but the prosecution withheld one in which Boblit admitted the homicide. The suppressed statement was discovered after conviction, and the Maryland courts granted a new trial only on punishment, not guilt.
Does due process require the prosecution to disclose a codefendant's confession favorable to the accused when it is material to punishment as well as guilt?
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, regardless of the prosecution's good or bad faith.
Yes. The prosecution's suppression of Boblit's confession violated due process because the evidence was favorable to Brady and material to punishment, so Brady was entitled to a new sentencing proceeding.
The Court reasoned that criminal trials must be fair and that the state's interest is not to win, but to ensure justice is done. Because the withheld confession bore directly on whether Brady personally committed the killing, it was relevant to the severity of punishment even if Brady's participation supported guilt for murder. The Court rejected any distinction based on prosecutorial intent, holding that suppression of material favorable evidence itself offends due process. Since the statement affected punishment rather than guilt, the proper remedy was a new trial limited to sentencing.
Brady is the foundational case establishing the prosecution's constitutional duty to disclose material exculpatory evidence, now known as the Brady rule. It shaped later doctrine on materiality and scope, including Giglio v. United States, 405 U.S. 150 (1972) (impeachment evidence), United States v. Agurs, 427 U.S. 97 (1976) (duty beyond specific requests), United States v. Bagley, 473 U.S. 667 (1985) (materiality standard), and Kyles v. Whitley, 514 U.S. 419 (1995) (prosecutor's duty to learn of favorable evidence known to the police).
Giglio v. United States, 405 U.S. 150 (1972) |
Abstain |
United States v. Agurs, 427 U.S. 97 (1976) |
Abstain |
United States v. Bagley, 473 U.S. 667 (1985) |
Abstain |
Kyles v. Whitley, 514 U.S. 419 (1995) |
Abstain |
Enter a case name or citation — get a structured brief where every case it cites is checked against real law.
Try Law Student Workbench →