Brady v. Maryland: Case Brief

Instructor: Brittany McKenna

Brittany is a licensed attorney who specializes in criminal law, legal writing, and appellate practice and procedure.

The Supreme Court's Brady v. Maryland decision addressed the government's duty to disclose evidence favorable to a defendant upon request. This lesson discusses the facts of Brady v. Maryland as well as the important details of the Supreme Court's landmark decision.

You are probably familiar with the stereotypical prosecutor character of television crime dramas: a handsome, well-groomed do-gooder who always does the right thing. But, of course, television rarely mirrors reality. What happens when a prosecutor isn't quite so 'up-standing'? In other words, how can the courts address a prosecutor who refuses to play by the rules?

The Supreme Court of the United States addressed this very question in the landmark Brady v. Maryland decision.

Facts of the Case

John Brady was arrested and prosecuted in a Maryland court for murder. Brady testified that although he was involved in the murder, his friend, Boblit, actually committed the murder. Brady's attorney had requested to see all of Boblit's statements to police in preparation for the trial, but a key piece was left out: a statement showing Boblit admitting to the murder. The jury found Brady guilty and sentenced him to death. Boblit was tried after Brady, receiving the same verdict and sentence.

Brady appealed his conviction on the grounds that the prosecutor had withheld exculpatory evidence from him. The evidence in question, Boblit's confession statement, played a central role in this appeal. Brady's case went all the way to the United State's Supreme Court, which heard the case and issued its opinion in 1963.

Question Presented to the Supreme Court

In the criminal justice system, the term exculpatory evidence refers to evidence favorable to the defendant that can be used to exonerate him or her. The phrase due process refers to the constitutional requirement that the government must respect every person's legal rights.

The question that the Supreme Court answered in Brady v. Maryland was: does the government (through the action or inaction of a criminal prosecutor) violate a defendant's due process rights by withholding exculpatory evidence?

Holding and Analysis of the Supreme Court

The Supreme Court held that withholding evidence violates a defendant's due process rights when the evidence is 'material either to guilt or to punishment'. In this context, evidence is considered material when there is 'a reasonable probability' that the defendant's conviction or sentence 'would have been different' had the evidence been disclosed in the first place.

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