Brady v. Maryland
The Court ruled that prosecutors violate a defendant's due process rights whenever they withhold evidence favorable to the accused that is material to guilt or punishment, regardless of whether the withholding was deliberate or accidental.
Even so, the Court upheld Maryland's decision to give the defendant a new sentencing hearing rather than a full new trial, because under Maryland law the withheld confession would not have changed the jury's decision on guilt.
“We now hold that the suppression by the prosecution of evidence favorable to an accused upon request violates due process where the evidence is material either to guilt or to punishment, irrespective of the good faith or bad faith of the prosecution.”
The core holding establishing what later became known as the Brady rule.
How it got here: After his conviction was affirmed, the defendant discovered the withheld confession, sought post-conviction relief, and Maryland's top court ordered a new trial limited to punishment; he then sought Supreme Court review.
The Case in Depth
What happened
A man and his companion were convicted of first-degree murder committed during a robbery and sentenced to death. Before trial, the man's lawyer asked to see his companion's statements to police; prosecutors withheld one statement in which the companion admitted doing the actual killing. The man did not learn of this statement until after his trial, conviction, and sentence were final.
The question before the Court
When prosecutors hid a co-defendant's confession before trial, did the defendant have a right to a whole new trial, or was a new sentencing hearing enough?
Why it matters
This decision created what is now called the 'Brady rule,' a bedrock requirement that prosecutors nationwide must turn over evidence that could help a defendant, whether on guilt or sentencing. It gives criminal defendants a constitutional tool to challenge convictions when prosecutors sit on favorable evidence, and it applies regardless of whether prosecutors acted in bad faith.
What changes now
The case returns to Maryland for a new sentencing hearing only, as the Maryland Court of Appeals had ordered; the defendant's underlying conviction for first-degree murder stands. The ruling itself is final on the federal constitutional questions presented, establishing a rule that prosecutors nationwide must follow going forward whenever they possess evidence favorable to a defendant that is material to guilt or punishment.
What this does not decide
The Court did not decide that every failure to disclose evidence entitles a defendant to a full new trial; that depends on whether the withheld evidence was actually admissible on the question of guilt. It also did not adopt a broad new discovery rule beyond the specific due-process violation found here, a limit Justice White's separate opinion pressed the Court to observe.
Concurrences and dissents
How the Justices voted
Majority (1). Justice Douglas (author).
Dissent (1). Justice Harlan (author).
Concurrence — Justice White
Justice White argued the Court did not need to decide the broad due process question about withheld evidence at all, since neither party had challenged the lower court's due process ruling; he called that discussion merely advisory. He would have limited the decision to the equal protection question actually in dispute and left broader discovery rules to legislatures and rulemaking rather than constitutional law.
Dissent — Justice Harlan
“I think the appropriate course is to vacate the judgment of the State Court of Appeals and remand the case to that court for further consideration in light of the governing constitutional principle stated at the outset of this opinion.”Harlan's proposed alternative disposition instead of resolving the case outright.
Justice Harlan, joined by Justice Black, argued the only real federal question was whether limiting the new trial to punishment violated equal protection, which depended on whether the withheld confession would have been admissible on guilt at the original trial. He found the Maryland Court of Appeals' opinion too unclear on that point and would have vacated and sent the case back for clarification rather than deciding federal due process questions. Read the full dissent →
How the Court got there
The legal reasoning, step by step
- The Court built on a line of cases holding that a prosecutor's use of evidence known to be false denies a defendant due process, and extended that principle to cover situations where prosecutors simply fail to correct false evidence or withhold favorable evidence altogether, even without deliberate deception.
- Applying that extended principle, the Court held that suppressing evidence favorable to an accused after a request for it violates due process whenever the evidence is material to either guilt or punishment, and that this rule applies whether the prosecutor's withholding was intentional or a good-faith mistake.
- The Court then turned to whether Maryland had to give the defendant a full new trial or could limit the new proceeding to sentencing alone, which turned on whether the withheld confession would have been admissible on the question of guilt under Maryland law.
- Maryland's constitution makes the jury 'the judges of law' in criminal cases, but the Court found, based on Maryland's own court decisions, that trial judges — not juries — still decide what evidence is admissible on the question of guilt.
- Because the Maryland Court of Appeals had already ruled that the withheld confession could not have reduced the offense below first-degree murder, the Court read this as a ruling that the confession was not admissible on the guilt question, so limiting the new trial to punishment did not deny the defendant any federal right.
Doctrinal impact
Cases affected by this decision
Reaffirms Mooney v. Holohan (294 U. S. 103)
The Court relied on and extended this case's rule against prosecutors using known false testimony to convict defendants.
Reaffirms Napue v. Illinois (360 U. S. 264)
The Court built on this case's extension of the rule to situations where prosecutors let false evidence go uncorrected.
Reaffirms Pyle v. Kansas (317 U. S. 213)
The Court relied on this case's broader phrasing of the rule against suppressing evidence favorable to the defense.