Case Brief
Citation: Brady v. Maryland, 373 U.S. 83 (1962)
Procedural History
This case is on appeal from an affirmed decision of the Maryland Court of Appeals. It was currently on remand only for the purpose of punishment.
Issue
Does withholding of evidence favorable to a defendant violate that defendant’s due process rights? Under the circumstances of this case, did limitations on new proceedings as to punishment only violate defendant’s due process rights?
Holding
The Supreme Court held that, in general, withholding evidence favorable to the defendant as to either guilt or punishment violates a defendant’s due process rights irrespective of the intentions of prosecutors. But for the purposes of this case, no, the defendant’s due process rights were not violated when his new trial was restricted to punishment only, as the evidence in question only pertained to his relative culpability and appropriate punishment, not his underlying guilt.
Facts
Brady (Petitioner) and accomplice, Boblit, were both convicted in a Maryland Court of the same murder (in the first degree) but in separate trials. At trial, Brady admitted his assistance in the planning and commission of the crime, but denied having personally committed the killing. Defense counsel admitted his client’s guilt at trial, explaining to the jury that they should find him guilty but not impose the death penalty due to his lesser culpability. Brady’s attorney, prior to trial, requested access to all of the accomplice’s statements to police, most of which were provided. However, one statement was withheld. The substance of that statement showed that the accomplice admitted to actually committing the murder. Defense Counsel, in post-conviction proceedings, raised the issue and demanded a new trial. The Maryland Court of Appeals agreed that the withholding of evidence violated due process, and