Brady v. Maryland is one of the landmark cases in criminal justice decided by the Supreme Court of the United States. The case was an appeal following the first-degree murder committed by two perpetrators, John L. Brady and Donald Boblit were both sentenced to death for first-degree murder. While the question of guilt was hardly disputed, the prosecution withheld Boblit’s confession that he committed the actual killing and Brady was not directly involved. What began as a simple appeal to make the prosecution provide evidence that can benefit the defendant ended with the Supreme Court asserting a legal doctrine that continues to influence procedural matters.
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Before delving into the details of the Supreme Court’s decision and its long-term impact, it is necessary to list the facts of the case. In mid-1958, Brady and Boblit, two Maryland residents, murdered their common acquaintance, a 53-year old William Brooks. While Brady participated in the crime, Boblit was the one to commit the actual murder. Moreover, the prosecution had an admissible confession on Boblit’s side that it was him rather than Brady who committed the crime (Brady v. Maryland). In a separate trial for each of the offenders, the jury, being the judge of both the law and the facts, ruled that they both were guilty of second-degree murder and sentenced them to death (Brady v. Maryland). Even though Brady’s counsel requested the prosecution to provide Boblit’s extrajudicial statements, the one where he confessed to being the one who committed the actual killing was withheld until after the sentencing (Brady v. Maryland). Since the defense built its case on the claim that Brady did not actually kill Brooks and, thus, deserved no capital punishment, withholding Boblit’s testimony directly harmed Brady’s cause.
While the original ruling for Brady was a death sentence, it was passed without enclosing Boblit’s testimony when the latter confessed to committing the actual killing. Due to the prosecution’s nondisclosure of this particular statement, it only came to the attention of the defense after the sentence was passed (Brady v. Maryland). When the defense learned about the new and potentially crucial piece of evidence, it appealed to the Maryland Court of Appeals. The ground for the appeal was that the prosecution’s nondisclosure denied Brady the due process of law (Brady v. Maryland). When reviewing the case, the Maryland Court of Appeals ruled that the prosecution did, indeed, deny Brady the due process by withholding evidence. Considering this, the court scheduled the case for the new trial on the question of punishment, but not the question of guilt (Brady v. Maryland). Dissatisfied with the verdict, the defense appealed to the Supreme Court of the United States, insisting that the new trial would consider the question of guilt and punishment alike.
There are two distinct parts to the Supreme Court’s ruling on this particular case. The first one is the Court’s confirmation of the ruling by the Maryland Court of Appeals in the part that pertains to the prosecution withholding the evidence from the defense. In the Court’s opinion, Boblit’s testimony about performing the actual killing was directly relevant to the question of Brady’s guilt and, as such, was undoubtedly favorable for the defense. Based on this, the prosecution withheld this information until after the trial, even though Brady’s defense requested to review Boblit’s testimony was a nondisclosure of evidence favorable to the accused. As a consequence, the Supreme Court ruled that such suppression of favorable evidence violated the due process that Brady was entitled to (Brady v. Maryland). The Court made this decision based on the due process clause found in the Fifth and the Fourteenth Amendments to the US Constitution. Thus, the first major part of the court’s ruling was that nondisclosure of requested evidence favorable to the defendant was against the law, and the new trial should be held for Brady.
The second part of the Supreme Court’s verdict on the case was affirming the corresponding second part of the ruling already made by the Maryland Court of Appeals. As mentioned above, the Maryland Court of Appeals ruled that the new trial for Brady would be limited to the question of punishment, effectively excluding the question of guilt. The Supreme Court affirmed that decision by ruling that limiting the new trial set for Brady to the question of guilt did not violate his right to due process (Brady v. Maryland). The reason why the Court made such a decision was that the facts of the case pointed to Brady participating in the crime despite not committing the actual killing that Boblit did. As a result, the new evidence would not exonerate Brady on the matter of guilt, even if it was present in the original trial. Based on this, the Court ruled that Boblit’s testimony was only admissible on the issue of punishment, but not the issue of guilt, which is why limiting the new trial to the former was correct.
The case has several important applications in criminal justice today. The first and most obvious one is the affirmation of the prosecution’s obligation to disclose the information favorable to the defendant, should such information be requested. In the Court’s own words, “Suppression by the prosecution of evidence favorable to an accused who has requested it violates due process” (Brady v. Maryland). This ruling brought forward what is known now as the Brady doctrine. The doctrine’s main point is that the prosecution has “a general duty to disclose information in its possession that is favorable to the defense,” irrespective of good or bad faith on its part (Crump 515). Even though the specifics of the doctrine’s application are sometimes divisive, the doctrine itself remains largely uncontroversial (Crump 515). Thus, the first aspect of the enduring importance of Brady v. Maryland for criminal justice is its unequivocal confirmation of the prosecution’s obligation to hand over the evidence favorable to the accused.
The second reason why Brady v. Maryland remains important in criminal justice today pertains to the second part of the Supreme Court’s ruling. As mentioned above, the Supreme Court affirmed the ruling by the Maryland Court of Appeals that the new trial should be limited to the question of punishment (Brady v. Maryland). This part outlines the requirement of materiality, which means that the Brady doctrine is only concerned with the evidence admissible on the questions of guilt or punishment and likely to affect the outcome. As noted by Crump, the information that is “not at all likely to affect the outcome at trial is not the kind of information with which Brady is concerned” (516). Hence, the second important influence of Brady v. Maryland in criminal justice is the clarification that nondisclosure of evidence only violates due process when it is admissible and material to either guilt or punishment.
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The third aspect that makes Brady v. Maryland consistently important in criminal justice today is, paradoxically, the implicit benefits it provides to the prosecution. At first sight, the obligation to disclose evidence favorable to the accused regardless of the prosecution’s good or bad faith is unequivocally disadvantageous to it. Accordingly, most commentators interpret the case “as a benefit to the defendant and a burden to the prosecutor” (Meyn 885). However, there is a structural benefit for the prosecution in the provisions of Brady. According to Meyn, the Supreme Court’s ruling on Brady v. Maryland effectively limited the due process review in criminal justice to the trial phase. As a result, it “fortified prosecutorial power over the distribution of information during pretrial proceedings” (Meyn 885). Considering that the vast majority of criminal cases are solved during the pretrial phase, the Brady doctrine may actually be a benefit to the prosecution.
As one can see, Brady v. Maryland is a landmark case in criminal justice that remains important in multiple respects. The prosecution’s nondisclosure of the evidence requested by the accused and potentially favorable for him served as grounds for an appeal first to the Maryland Court of Appeals and then the Supreme Court. The latter confirmed the verdict of the lower court and ruled that the prosecution has a duty to provide the information favorable to the defense, should it be requested. It also specified that this ruling only applies to the evidence that is admissible and material to the questions of guilt and punishment. The case’s persistent importance in criminal justice is due to the Brady doctrine incorporating prosecutorial obligations and materiality requirements as well as the implicit effect of limiting due process review to the trial phase.
“Brady v. Maryland, 373 U.S. 83 (1963).” US Supreme Court, Web.
Crump, David. “Brady v. Maryland, Attorney Discipline, and Materiality: Failed Investigations, Long-Chain Evidence, and Beyond.” Hofstra Law Review, vol. 45, no. 2, 2016, pp. 515-536.
Meyn, Ion. “Flipping the Script on Brady.” Indiana Law Journal, vol. 95, no. 3, 2020, pp. 883-921.