Brady v. Maryland
Facts
The case was argued in the Supreme Court of the United States between 18 to 19 th March 1963 and was subsequently decided on 13 th May of the same year (Brady v. Maryland, 1963). Justice Douglas determined the decision, which was later declared by Justice Brennan. The parties to the case were Brady, the petitioner, and the state of Maryland as the respondent. Prior to the petition, Brady and Boblit had been found culpable of first-degree murder thereby convicted to death. The Court of Appeals of Maryland affirmed this verdict. The accused were adjudicated separately with Brady admitting to participation but not in the actual act of murder, which he claimed Boblit did. The prosecution of the case withheld evidence of Boblit’s admission to the homicide, which was only discovered after the convictions had been made. In light of the new evidence, the petitioner pushed for a retrial which was upheld by the Court of Appeals. Particularly, the court cited that withholding evidence denied the petitioner the necessary process of the law pursuant to the Fourteenth Amendment and the ruling regarding Pyle v. Kansas. Consequently, the Supreme Court remanded the case for a retrial subsequent to the exculpatory evidence but on the question of punishment rather than guilt.
Issues
One major issue present in the case is that the prosecution withheld a fundamental piece of evidence in the form of a confession that revealed Boblit as the actual murderer. Moreover, the evidence dated 1958 was discovered after the trial, conviction, and sentencing of Brady to death making. Thus, this formed the basis for appeal and retrial. Another issue was the inquiry of the evidence to ascertain if it were enough to lift the death penalty off Brady’s head now that his guilt was not in question. Another prominent issue was the indecisiveness of the court on whether Brady’s constitutional rights had been infringed when the Court of Appeals confined the retrial to punishment only and whether the jury could overrule the trial court decisions regarding the admissibility of evidence.
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Decisions
In the initial trial, the court found both Brady and Boblit guilty thereby imposing capital punishment on both parties pursuant to Maryland state law. In the light of the exculpatory evidence, the Court of Appeals found that the prosecution’s suppressive action deprived Brady apt process of the law thereby remanding the litigation to retrial under strict confinements of punishment rather than guilt. This was a verdict that was also arrived at by the Supreme Court.
Reasoning
As reported by Post (2015) the repression of crucial evidence by the prosecution justified a retrial regardless of the good or bad faith of the prosecution. Additionally, the petitioner was entitled to the right to equal protection under the Fourteenth Amendment.
Dissenting opinions
Dissenting opinions were from Justice Harlan and Justice Black who stated that an affirmation would solely suffice if Boblit’s statement would have been tenable at the initial trial but only on the question of guilt. To this end, the two held that there was only one federal issue; whether the State Court of Appeals directive for retrial with the restriction on the question of punishment denied Brady the right to equal protection.
Giglio v. United States
Facts
The case was argued in the Supreme Court of the United States on 12 th October 1971 and was decided on 24 th February 1972 (Giglio v. United States, 1972). The petitioner, Giglio, had initially been found culpable for handling counterfeit money and was convicted to five years imprisonment. Before an appeal was made in the Court of Appeals, new evidence initially suppressed by the government regarding its promise to a key witness came to light. As such, the court gave certiorari in the determination of whether the new evidence was sufficient for a retrial under the due process criteria of Brady v. Maryland (1963) and Napue v. Illinois , (1959).
Issues
A substantial issue in the case was the withholding of information by the government regarding its promise to the key witness pertinent to immunity if he testified for the government. Another issue was the credibility of the evidence in the retrial following the non-disclosure by the prosecution.
Decisions
The court noted that a new trial was necessary and that the initial judgement and conviction be reversed and the case remanded for further considerations.
Reasoning
The Supreme Court found that neither the prosecution assistant’s dearth of authority nor his non-fulfillment to notify his associates and superiors was controlling. Thus, the prosecution’s mandate to provide complete relevant evidence to the court was not met thereby constituting an infringement of the due process.
Dissenting Opinions
All members of the jury and court affirmed the decision except Mr. Justice Powel and Mr. Justice Rehnquist who were not involved in the decision of the case or its consideration (Justia, 2018).
Relevant Evidence
Relevant evidence is material that has a substantial tendency of making a fact more or less credible than it would be minus the material. Additionally, the matter under scrutiny has to be of consequence in determining the action as per Rule 401, (National Paralegal, 2018). The relevance of the evidence here requires both legal and logical significance. The material evidence has to be admissible and cannot be used to demonstrate a fact that is inadmissible. However, according to Rule 403, the evidence can be excluded regardless of its relevance if there is a risk of unfair preconception, undue delay, misleading of the jury, or confusion of the issues under determination.
Exculpatory Evidence
According to Legal Dictionary (2018), exculpatory evidence is any evidence in criminal litigation that tends to vindicate the defendant of any guilt. If the prosecutor is found to have withheld or suppressed evidence either after the trial and conviction or during the trial, then this evidence is referred to as exculpatory evidence. This evidence can result in dismissal of the trial or retrial in case of conviction. The importance of exculpatory evidence during trial is that it invokes the Fourteenth Amendment that specifies the right of equal protection. Thus, the invocation could exonerate the defendant or even lead to the dismissal of the trial citing the innocence of the defendant or infringement by the prosecution or respondent. It is under the restrictions of the exculpatory evidence that the Brady v. Maryland case was remanded for a retrial after the prosecution withheld material evidence while that of Giglio v. the United States was reversed and remanded for trial as well after the discovery that the government suppressed an immunity deal with a key witness. A similar case with the same outcomes as the cases above is the Buffey v. Warden where the prosecution withheld exculpatory evidence during the negotiation of a plea bargain (Post, 2015). Others include United States v. Avellino (1998), White v. United States (1988) and Sanchez v. United States (1995).
References
Brady v. Maryland , 373 U.S. 83, 83 S. Ct. 1194, 10 L. Ed. 2d 215 (1963).
Giglio v. United States , 405 U.S. 150, 92 S. Ct. 763, 31 L. Ed. 2d 104 (1972).
Justia. (2018). Giglio v. United States, 405 U.S. 150 (1972). Retrieved from https://supreme.justia.com/cases/federal/us/405/150/
Legal Dictionary. (2018). Exculpatory. Retrieved from https://legaldictionary.net/exculpatory/
National Paralegal. (2018). What is Relevant Evidence? Retrieved from http://nationalparalegal.edu/Slides_New/Evidence/SH/Slides_05.pdf
Post, D. (2015). Constitutional right to obtain exculpatory evidence from prosecutors extends to plea-bargain phase. The Washington Post . Retrieved from https://www.washingtonpost.com/news/volokh-conspiracy/wp/2015/11/18/constitutional-right-to-obtain-exculpatory-evidence-from-prosecutors-extends-to-plea-bargain-phase/?noredirect=on&utm_term=.e489d7e68965
