United States v. Williams
Citation: 504 U.S. 36 (1992)
Facts
Williams was indicted by a federal grand jury. He argued the indictment should be dismissed because the prosecutor had failed to present substantial exculpatory evidence to the grand jury.
Issue
Does a federal court have supervisory power to require prosecutors to present exculpatory evidence to a grand jury?
Holding
No. Federal courts may not exercise their supervisory power to impose a duty on prosecutors to present exculpatory evidence to the grand jury. The grand jury is an independent body and its proceedings are not subject to judicial supervision in this manner.
Rule
The grand jury is a constitutional institution that operates independently of both the courts and the executive branch. Courts lack supervisory authority to impose disclosure obligations on prosecutors before the grand jury beyond what the Constitution itself requires.
Significance
- Strongly affirms grand jury independence and the wide latitude of prosecutorial discretion before the grand jury
- Establishes that there is no due process or supervisory power obligation to present exculpatory evidence to a grand jury (contrast with Brady v. Maryland obligations at trial)
- Underscores that the grand jury screens charges but does not constitute a full adversarial proceeding