Brady v. Maryland (1963)
Brady v. Maryland (1963): Prosecutors Must Disclose Favorable Evidence
Withholding evidence that helps the defense violates due process.
Background
John Brady was charged with murder along with an accomplice. Brady admitted involvement but claimed his co-defendant was the actual killer. The prosecution withheld a written confession from that accomplice confirming Brady’s claim. Brady was convicted and sentenced to death. The hidden confession surfaced later, revealing the prosecution’s failure to disclose critical exculpatory evidence.
Questions Presented
- Does the prosecution violate due process by suppressing evidence favorable to the accused when the evidence is material to guilt or punishment?
Majority Opinion — Justice William O. Douglas
Holding: The Due Process Clause requires prosecutors to disclose evidence favorable to the accused that is material to guilt or punishment.
Douglas explained that the criminal justice system demands fairness — not victories at any cost. When the State hides evidence that could change the outcome of a trial, it denies the defendant a fair opportunity to defend themselves. The Court ruled that suppression of material exculpatory evidence violates due process regardless of the prosecution’s intentions.
Brady obligations apply to:
- Evidence that undermines guilt
- Evidence that reduces punishment
- Evidence that impeaches a State’s witness
Texas prosecutors must affirmatively disclose favorable information. Violations often lead to overturned convictions, new trials, or sentence reductions. Montgomery County defense lawyers aggressively investigate and demand Brady materials, including police misconduct files, inconsistent witness statements, and forensic issues. If the State fails to provide such evidence, suppression hearings and post-conviction relief may follow.