Brady v. Maryland
Citation: 373 U.S. 83 (1963)
Facts
John Leo Brady was convicted of murder and sentenced to death. After trial, Brady discovered that a companion had confessed to the actual killing, and that the prosecution had suppressed that confession despite Brady’s pre-trial request for any statements made by his companion. Brady did not contest his participation in the crime but argued the withheld confession was relevant to the punishment phase.
Issue
Whether the suppression of evidence favorable to the accused by the prosecution, after the defendant’s request for it, violates due process.
Holding
The Supreme Court held that suppression of evidence favorable to the accused upon request violates due process where the evidence is material either to guilt or punishment, regardless of the prosecution’s good or bad faith.
Rule
The prosecution must disclose evidence that is favorable to the accused and material to guilt or punishment. Suppression of such evidence violates the Due Process Clause of the Fourteenth Amendment.
Significance
Brady established the constitutional obligation of prosecutors to share exculpatory evidence with the defense — the “Brady doctrine.” Subsequent cases (e.g., Giglio, Strickler v. Greene) expanded its scope. Brady violations remain one of the most litigated issues in post-conviction proceedings and are central to wrongful conviction scholarship.