Key Legal Principle: Whether suppression of evidence by the prosecution violates due process under the Fourteenth Amendment.
Background
Brady and Boblit were convicted of first-degree murder and sentenced to death.
Brady admitted participation in the crime but claimed Boblit did the actual killing.
Key Issue: Prosecution withheld a statement by Boblit confessing to the actual murder.
Brady's lawyer had requested access to all of Boblit's statements before the trial, but the crucial July 9, 1958, statement was not disclosed.
Legal Proceedings
Initial Outcome: Brady's conviction and death sentence were affirmed by the Maryland Court of Appeals.
Brady petitioned for a new trial based on suppressed evidence.
The Maryland Court of Appeals eventually ordered a retrial limited to the question of punishment.
Supreme Court Decision
The Supreme Court held that the suppression of evidence favorable to the accused upon request violates due process when the evidence is material to either guilt or punishment.
The decision emphasized that a fair trial is the objective of the justice system, not merely convicting the guilty.
The Court ruled that the suppression of Boblit's confession denied Brady due process.
Key Legal Principles
Due Process Clause (14th Amendment): The prosecution must disclose evidence favorable to the accused that is material to guilt or punishment.
Material Evidence: Evidence that could influence the outcome of the trial or punishment decision.
Fair Trial: Ensures justice is done, not only in convicting the guilty but also in treating the accused fairly.
Separate Opinions
Justice White's Opinion: Suggested that broader questions of due process should be left to legislative or rule-making bodies, rather than being broadly defined by the Court.
Justice Harlan's Dissent: Argued that Brady was denied equal protection under the Fourteenth Amendment because the new trial was restricted to punishment.
Implications
The ruling established the precedent that withholding evidence favorable to the defendant violates their constitutional rights.
Set a standard for the disclosure of exculpatory evidence in criminal trials.
Footnotes and References
Various legal precedents and prior cases related to the due process and equal protection rights were cited, including Mooney v. Holohan, Pyle v. Kansas, and Napue v. Illinois.
Footnotes provided historical and legal context for interpretations and applications of due process and jury roles in state law.