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Evidence Procedure

Brady v. Maryland

373 U.S. 83Supreme Court of the United States1963

Video Brief

The Rule Prosecutors Cannot Ignore

Brady v. Maryland requires prosecutors to disclose material evidence favorable to the accused when it bears on guilt or punishment. The rule protects the fairness of criminal trials and applies regardless of whether the prosecution acted in good or bad faith.

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Background

John Brady and a companion, Charles Boblit, were tried separately for first-degree murder in Maryland and sentenced to death. Brady admitted participating in the crime but said Boblit committed the actual killing. Before trial, Brady's lawyer requested Boblit's statements.

Prosecutors disclosed some statements but withheld one in which Boblit admitted the homicide. Maryland later ordered a new trial on punishment only.

The dispute reached the courts because the police action, prosecution, civil-rights claim, or government policy raised a constitutional question that could not be answered by the facts alone.

Issue Before the Court

Does the prosecution violate due process by suppressing evidence favorable to an accused when that evidence is material to guilt or punishment, even if the suppression was not in bad faith?

In plain English, the court had to decide where police authority ended and constitutional protection began under the facts of this case.

Decision

Yes. The Supreme Court held that suppression by the prosecution of evidence favorable to an accused who requested it violates due process when the evidence is material either to guilt or to punishment, regardless of good faith or bad faith. The Court affirmed Maryland's decision limiting Brady's new trial to punishment because the suppressed confession affected punishment, not guilt under the state court's view.

The decision matters because brady became the foundation for prosecutors' constitutional duty to disclose material favorable evidence to the defense. It treats fairness in criminal trials as a due process requirement, not a discretionary courtesy.

Plain-English Implications for Police Work

If the government has important evidence that helps the accused on guilt or punishment, it cannot hide it. A fair conviction requires fair disclosure.

Brady obligations shape criminal discovery, police evidence handling, prosecutor training, post-conviction litigation, and law-enforcement documentation practices. Reports, statements, recordings, impeachment material, and forensic issues may all matter if they are favorable and material.