Evaluating and applying relevant evidence

Legal Concept of Relevant Evidence

Brady v. Maryland, 373 U.S. 83 (1963)

Facts: Defendants Brady and Boblit were convicted of murder by the state of Maryland, with Brady admitting participation in the crime but stating that Boblit committed the actual act of killing the victim. Boblit confirmed this fact in a written statement recording his personal confession, but during the criminal proceedings prosecutors elected to withhold Boblit's confession from the court, as well as from Brady and his attorney. Upon being convicted of the murder, Brady challenged the decision on the basis of potential violations of the Fourteenth Amendment, which guarantees those accused of criminal conduct the right to due process. The Maryland Court of Appeals affirmed Brady's conviction, but remanded the case for retrial to reassess the question of punishment.

Issues: The prosecution's choice to withhold Boblit's written confession irrevocably altered the sentencing process for Brady, as the court was never made aware that he did not actually commit the violent acts which ended the victim's life. While Brady's participation in the crime warranted a murder conviction in light of judicial precedent on the issue of accomplices to violent crimes which result in death, the court may have rendered a reduced sentence in light of the mitigating circumstances present in his case. By withholding the written confession, prosecutors violated Brady's due process right to be made aware of the evidence to be presented against him, as awareness of the written confession would have allowed Brady's attorney to seek a reduced sentence.

Decisions: The Supreme Court ultimately ruled that the prosecution's decision to withhold exculpatory evidence violated Brady's right to due process "where the evidence is material either to guilt or to punishment." Although the Warren Court found that under Maryland state law the written confession which was withheld could not have exculpated the defendant from guilt, but that the evidence was material to the degree of punitive action he would face at sentencing. The Maryland Court of Appeals' ruling was affirmed, and the precedent for so-called Brady Disclosure was set.

Reasoning: Any exculpatory evidence of which the prosecution has knowledge of must be immediately submitted to the court for review, which includes the defense attorney and the defendant. This is a long-held legal maxim in American jurisprudence dating back to the Fourteenth Amendment's guarantee of due process for those accused of criminal or civil violations. Anything known as "Brady Material" -- the production of a viable alibi, DNA evidence or eyewitness statements -- must be readily produced for appraisal by defense attorneys in accordance with a defendant's right to due process, and in this case Boblit's written confession would have warranted a potential reduction in sentence after Brady was convicted of murder.