Supreme Court Reiterates the Duty of the Prosecution to Disclose All Potentially Exculpatory Evidence

The Supreme Court of the United States decided the landmark case of Brady v. Maryland in 1963. 373 U.S. 83. While the Brady doctrine stemming from this case is nuanced and has been addressed many times over the past few decades – at its core, Brady imposes a duty upon the prosecution to turn over to the defense in a criminal trial all evidence which tends to cast doubt upon a defendant’s guilt. In the 2012 case of Smith v. Cain, the Court both restated and reaffirmed the Brady holding. Smith v. Cain, 132 S. Ct. 627 (2012).

In Smith v. Cain, Defendant Smith was charged with killing five people during an armed robbery. At trial, a witness identified Smith as the first gunman to come through the door. No other witnesses and no physical evidence implicated the defendant in the crime. After being convicted, the defendant obtained the notes of a detective who had worked on his case, which contained statements by the identification witness that conflicted with his testimony identifying Smith as a perpetrator. Smith alleged that the prosecution’s failure to disclose the detective’s notes violated Brady.

The Supreme Court of the United States agreed, finding that the witness’s undisclosed statements alone undermined confidence in the defendant’s conviction. The Court held that the statements at issue were plainly material to the determination of the inmate’s guilt, since the witness’s testimony was the only evidence linking the inmate to the crime, and since the witness’s undisclosed statements directly contradicted the witness’s testimony at trial. The Court reversed the state trial court’s judgment and remanded the case for further proceedings.

If you have been charged with a crime and believe your rights may have been violated, please contact the Law Offices of Marc Neff for a confidential consultation: 215-563-9800 or via email at marc@nefflawoffices.com.