Brady v Maryland, 373 US 83Supreme Court (1963)
The Court of Appeal of Maryland was granted an order of certiorari to consider whether the petitioner had been deprived of a constitutional right when the Court of Appeal ordered a new murder trial restricted to the question of punishment only. The Appeals Court granted a retrial. There was however a second appeal to the Supreme Court where the ruling of the Court of Appeals was affirmed, with the Court holding that the evidence suppressed was material to the punishment of the defendant but couldn’t have exculpated him.
The petitioner, Brady, and his companion, Boblit, had been tried and convicted of murder in the first degree. This murder had been committed in the perpetration of a robbery and the corresponding punishment in the state of Maryland was life imprisonment or death. The trials were held separately and in his trial, Brady admitted to participating in the crime. He however averred that Boblit had done the actual killing. Prior to this, his legal counsel had requested permission to examine Boblit’s extra-judicial statements but the prosecution, though disclosing some statements, specifically withheld the statement where Boblit had admitted committing the actual homicide. On appeal the Court of Appeals held that although the suppression of evidence denied the petitioner due process of the law, this only warranted a retrial on the question of punishment and not guilt.
The issue arising was whether the Court of Appeal had erred in its decision to restrict the trial to the question of punishment and whether this action by the Court had deprived the petitioner of a constitutional right.
It was held that if an accused person requests for information that would be favorable to him, and the prosecution suppresses that information, whether in good or bad faith, this act by the prosecution shall be deemed to be a violation of the due process if that evidence is material either to the finding of guilt of the defendant or to the punishment meted out to him.
If the prosecution is allowed to withhold evidence that would exculpate the accused person or reduce his penalty, this restructures a trial to the disadvantage of the defendant. This does not conform to the standards of justice where it is a fundamental requirement for the law to protect an accused person with the same firmness it protects the society.
The Supreme Court affirmed the ruling of the Maryland Court of Appeals.