People v. Garrett
Citation: (California case — Brady/Giglio disclosure context)
Facts
The prosecution failed to disclose information bearing on the credibility of a key witness — specifically, evidence that the witness had a deal with or expectation of benefit from the government in exchange for testimony. The defendant was convicted and later sought relief based on the non-disclosure.
Issue
Does the prosecution’s failure to disclose impeachment evidence about a witness’s deal with the government violate due process under Brady v. Maryland and Giglio v. United States?
Holding
Yes. The prosecution’s suppression of impeachment evidence material to the defendant’s guilt or punishment violates due process. Deals or promises made to witnesses are Giglio material that must be disclosed.
Rule
Brady/Giglio disclosure — witness deals: The prosecution must disclose all agreements, deals, or expectations of leniency made to witnesses who testify for the government. Such evidence is impeachment material; its suppression violates due process if there is a reasonable probability the result would have been different had it been disclosed.
Significance
- Applies Giglio v. United States (1972) in the state context
- Impeachment evidence of witness credibility is Brady material
- Illustrates the broad scope of Brady obligations — extends beyond exculpatory evidence to any material affecting witness credibility