Turner v. United States

Background

In 1985 seven men were tried together for the kidnapping, armed robbery, and murder of Catherine Fuller. The prosecution's case relied on cooperating witnesses and multiple eyewitnesses who described a large group attack. Each defendant argued he was not part of that group. The jury convicted all seven. Years later, during postconviction review, defense teams obtained prosecutor files showing seven pieces of evidence that had not been disclosed at trial. The local trial court held a 16-day hearing and found the withheld material was not "material"; the D.C. Court of Appeals affirmed.

Reasoning

The Court addressed only whether the undisclosed evidence was material enough under Brady to require a new trial. Materiality asks whether there is a reasonable probability the trial result would have been different. The withheld items included identification of a possible alternative suspect (James McMillan), a passerby’s note of groans from the garage, earlier witness statements suggesting fewer attackers, and notes undermining witness credibility. After reviewing the full record, the Court found that the new evidence was weak, cumulative, or too inconsistent with multiple corroborating witnesses to undermine confidence in the verdict.

Real world impact

The decision leaves the convictions intact and denies new trials for the seven defendants. It shows that Brady relief is limited when many witnesses independently describe the same basic event. The opinion also reiterates that prosecutors should disclose favorable evidence, but it confirms a high factual bar for proving that nondisclosure likely changed the outcome.

Dissents or concurrances

Justice Kagan dissented, arguing the withheld evidence together could have let the defendants present a united alternative-perpetrator defense and might have flipped at least one juror; she would have ordered a new trial.