Facts of the Case

In 1958, John Brady and Charles Boblit were both convicted of first-degree murder and sentenced to death for the killing of William Brooks during a robbery in Maryland. Brady admitted his involvement in the robbery but claimed that Boblit was the one who actually committed the murder. During Brady’s trial, his defense requested access to Boblit’s statements, but the prosecution withheld a statement in which Boblit admitted to being the killer. Brady was convicted and sentenced to death. After discovering the withheld statement, Brady’s defense appealed, arguing that the suppression of this evidence violated his constitutional rights.

Constitutional Question

Does the prosecution’s suppression of evidence favorable to a defendant who requests it violate the Due Process Clause of the Fourteenth Amendment?

Arguments

For Brady:

• The prosecution’s failure to disclose exculpatory evidence (Boblit’s confession) violated Brady’s right to due process.
• The suppression of this critical evidence prevented Brady from receiving a fair trial, as it may have influenced the sentencing decision.
• A fair judicial process requires that the defense have access to all material evidence that could affect the outcome of the case.

For Maryland (prosecution):

• The state argued that the suppression of Boblit’s confession was a harmless error because the evidence still pointed to Brady’s involvement in the crime.
• The prosecution contended that Brady was still culpable under Maryland law because he participated in the robbery that led to Brooks’ death, regardless of whether he was the actual killer.

The Decision

The Supreme Court, in a 7-2 decision, ruled in favor of Brady. Justice William O. Douglas, writing for the majority, held that the suppression of evidence by the prosecution, which is favorable to the defendant and material either to guilt or to punishment, violates the Due Process Clause of the Fourteenth Amendment. The Court reasoned that withholding Boblit’s confession deprived Brady of a fair trial, as the evidence was material to the issue of whether Brady deserved the death penalty. The Court established the rule that the prosecution must disclose any exculpatory evidence that is material to the defense’s case, a principle now known as the “Brady Rule.”

Significance

Brady v. Maryland is a landmark case that established the requirement for prosecutors to disclose exculpatory evidence to the defense. The decision emphasized the importance of fairness and transparency in the criminal justice system, particularly when it comes to ensuring that defendants receive a fair trial. The “Brady Rule” has become a fundamental aspect of due process rights, protecting defendants from wrongful convictions by ensuring that all evidence favorable to the defense is disclosed. The ruling has had a profound impact on criminal procedure, shaping the standards for prosecutorial conduct and the disclosure of evidence in criminal trials.