Case Briefs
Brady v. Maryland, 373 U.S. 83 (1963)
Facts: The court adjudicated the case on 18-19 March 1963 and decided on 13 May 1963 (Brady v. Maryland, 1963). Although Brady and Boblit were suspects in the murder case, they had separate trials. Although Brady admitted participating in the crime, he denied playing a central role in committing the murder. The jury charged Brady with the first-degree murder and gave him capital punishment. Before the trial, Brady’s counsel made a request to preview Boblit’s extrajudicial statements, but the prosecutor withheld the statement pertaining to Boblit’s confession to the actual murder. After sentencing, Brady realized that the trial court suppressed exculpatory evidence and filed for an appeal.
Issue: The issue raised was whether the prosecutor ought to comply with the Due Process Clause, which requires the provision of evidence that exonerates the defendant.
Decision: The appellate court re-examined the case and ruled that the trial court inappropriately suppressed exculpatory evidence, and thus, violated the due process.
Reasoning: The prosecution ought to hand over evidence relating to the defendant’s innocence or guilt in a due process to the defense. Withholding of both incriminating and exonerating evidence is tantamount to the violation of due process (Brady v. Maryland, 1963). The clause of the due process compels the prosecution to provide the defendant’s incriminating or exonerating evidence with or without request.
Discerning opinion
Critics do not agree with the decision and the procedure employed in arriving at the ruling. They held that the case only presented a solitary question focusing on the violation of the right to equal protection and punishment, which did not guarantee the need for a fresh trial. The presentation of the question would have been legitimate if the court had ruled guilt on trial. Therefore, the suitable approach would have been to nullify the appeal and refer the case to the trial court for advance adjudication.
Giglio v. United States, 405 U.S. 150 (1972)
Facts: The court argued the case on 12 October 1971 and decided on 24 February 1972. Giglio was a suspect in a forgery case together with Taliento. During the trial, Taliento denied getting leniency for his testimony against Giglio. A new prosecutor did not know about the promise made to Taliento, and thus, did not amend his testimony appropriately. The court convicted Giglio and sentenced him to five years in prison, which he appealed; however, he learned of Taliento’s immunity after filing his appeal (Giglio v. United States, 1972). To assess if the prosecutor provided required evidence and complied with the due process, the Supreme Court granted certiorari.
Issue: The issue revolved around whether the suppression of exculpatory evidence violated the due process and warranted a new trial. Besides, the issue was whether the failure to divulge the promise of leniency emanated from deliberate deception or sheer negligence.
Decisions: The Supreme Court reversed the appellate court’s judgment and the trial court’s conviction of the defendant. Ultimately, the court adjourned the case and requested for a fresh trial.
Reasoning: The court ruled that the government failed to divulge exculpatory evidence by suppressing the promise made to Taliento, and thus, breached the due process of trial. Further, the prosecution presented Taliento’s testimony as evidence, yet it was false (Giglio v. United States, 1972). Since the prosecution has a legal responsibility to disclose exculpatory evidence, it was irrelevant that the prosecutor who tried Giglio was oblivious of exonerating evidence.
Discerning opinion: The dissenters argued that the nondisclosure of evidence falls within the general rule, and thus it is of concern that the disclosed evidence, even if it useful to the defense, does not necessitate a new trial when it is not likely to change the verdict.
Questions
What is the relevant evidence?
Relevant evidence is a form of evidence that directly relates to the issue discussed or disputed. For evidence to be relevant, there must be a logical connection between it and the fact that it allows one to prove or disprove a case (Ingram, 2014). Therefore, any evidence presented to be admissible must be relevant.
What is exculpatory evidence?
In a criminal trial, exculpatory evidence is a form of evidence that proves innocence and exonerates a defendant. The evidence may be documentary evidence, a physical exhibit presented in court, testimony, circumstantial evidence, or direct evidence (Imwinerlried & Garland, 2015). The court regards evidence as exculpatory if it shows that a defendant might not be guilty of a crime in a trial.
What is the importance of exculpatory evidence during a trial?
In a trial, exculpatory evidence is important because it provides a way of validating cases raised by the prosecution. In Giglio v. United States, the jury established that prosecutor’s duty to divulge exculpatory evidence extends beyond the information in their possession. In Brady v. Maryland, the U.S. Supreme Court ruled that the prosecution should share both incriminating and exonerating evidence with the defense (Hopper & Marsh, 2016). Moreover, exculpatory evidence allows defendants to prove their innocence and get justice during a trial.
Any further evidence that is appropriate.
In sticker v. Greene, the U.S. Supreme Court established that the prosecutor has a duty to divulge exculpatory evidence to the court without a request getting a request from a defendant. Physical and substantive exculpatory evidence has a significant impact for they can reverse the ruling or mitigate the sentence. In addition, the case of Tennison v. City of San Francisco, the court vacated the conviction of the accused and declared innocence based on exculpatory evidence, which inspecting officer withheld.
References
Brady v. Maryland, 373 U.S. 83 (1963).
Giglio v. United States, 405 U.S. 150 (1972).
Hopper, L., & Marsh, J. (2016). Treatment of Brady V. Maryland Material in United States District and State Court’s rules, orders, and policies: Report to the Advisory Committee on Criminal Rules of the Judicial Conference of the United States. New York, NY: Penny Hill Press.
Imwinerlried, E., & Garland, N. (2015). Exculpatory evidence: The accused’s constitutional right to introduce favorable evidence. Dayton, OH: Michie
Ingram, J. (2014). Criminal evidence. New York, NY: Routledge.