Brown, Warden v. Chaney

1985-02-25

Headline: Court refuses to review death-row inmate’s case, leaving appeals court’s vacatur of his death sentence in place while raising unresolved questions about prosecutors’ duty to disclose evidence at sentencing.

Holding: The Justices denied review, leaving intact the appeals court’s decision vacating the death sentence and declining to resolve disputed questions about when prosecutors must disclose evidence at sentencing.

Real World Impact:

Leaves the appeals court’s vacatur of the death sentence in place.
Highlights uncertainty about prosecutors’ disclosure duties at sentencing.
Creates continued circuit split over specific versus general evidence requests.

Topics: death penalty, prosecutor disclosure, withheld evidence, sentencing rules, criminal appeals

Summary

Background

A man convicted of kidnapping and murdering two women was tried, convicted of murder, and sentenced to death after phone calls traced to his home and a palm print on a pay-phone receiver helped link him to the crimes. Before trial his lawyers asked prosecutors for broad categories of interview reports and statements. Four FBI records were later discovered that had not been turned over; they did not point to his innocence but tended to suggest other people might have been involved.

Reasoning

A federal district court denied relief, but the Court of Appeals vacated the death sentence, finding the withheld reports could have affected jurors’ views about possible accomplices and therefore were material to sentencing. The Supreme Court denied review of the appeals court’s decision. The dissenting opinion explained that the case raises unsettled questions about how specific defense requests must be and what kind of withheld information is “material” at sentencing, citing prior decisions that govern when prosecutors must disclose evidence.

Real world impact

Because the Supreme Court refused to hear the case, the appeals court’s decision stands for now, affecting this man’s sentence. The dispute highlights conflicting rules in lower courts about how much prosecutors must disclose and whether the rules that apply at trial should be applied the same way at sentencing. The practical result is continuing uncertainty about disclosure duties in death-penalty and other sentencing proceedings.

Dissents or concurrances

Chief Justice Burger, joined by two colleagues, dissented from the denial of review and urged the Court to resolve these important and recurring questions about disclosure and sentencing.