Wood v. Bartholomew

Background

The case involves Dwayne Bartholomew, who admitted robbing a Tacoma laundromat where the attendant was shot and killed. His defense said the gun fired accidentally twice. Two eyewitnesses, his brother Rodney and Rodney’s girlfriend Tracy, testified that Bartholomew said he planned to leave no witnesses and later admitted shooting the attendant. Before trial, the prosecution had polygraph tests of both witnesses; neither test was disclosed to the defense. The tests were inadmissible under state law. After exhausting state remedies, Bartholomew filed a federal habeas action claiming the nondisclosure violated Brady, and the Ninth Circuit reversed the district court based on speculation that the tests might have led to better defense preparation.

Reasoning

The Court addressed whether failing to disclose the polygraph results created a reasonable probability of a different trial outcome. The Court noted the tests were inadmissible under state law and therefore not trial evidence. It rejected the Ninth Circuit’s speculation that disclosure would have led to depositions or new evidence. The Court relied on trial counsel’s statement that the tests would not have changed cross-examination, the district court’s opportunity to question Rodney with the information and find no contradictions, and the strength of the physical and witness evidence. The Supreme Court reversed the Ninth Circuit and remanded for further proceedings.

Real world impact

The ruling means undisclosed, inadmissible polygraph results alone do not justify overturning a conviction. It stresses that speculation about hypothetical follow-up discovery is insufficient to meet the Brady "reasonable probability" test. The opinion also emphasizes the costs of granting habeas relief and gives weight to trial counsel’s strategic judgments.

Dissents or concurrances

Four Justices (Stevens, Souter, Ginsburg, Breyer) dissented from the summary disposition of the case.