Cases Summary: Brady v. Maryland; Giglio v. United States; United States v. Agurs

The following three US Supreme Court cases place emphasis on the prosecution duty to disclose to the defense evidence in its possession favourable to the defendant: Brady v. Maryland, 373 U.S. 83 (1963), Giglio v. United States, 405 U.S. 150 (1972) and United States v. Agurs, 427 U.S. 97 (1976).

• Brady v. Maryland, 373 U.S. 83 (1963)

In this case, both defendants Brady and Boblit were suspected of murder, but Brady claimed that he did not  kill, although he participated in the criminal activity. Boblit confessed that he committed murder by himself. Brady was found guilty and sentenced to death. After sentencing, Brady learned of the suppression of Boblit’s statement. Brady appealed because he claimed that the suppression of the statement was violation of his Constitutional right to Due Process. The key issue in this case was if the prosecution must turn over evidence favourable to the defense under the Due Process Clause. The court held that suppression of the statement by prosecutor was unconstitutional. The Supreme Court affirmed the court’s decision. Due process requires turning over the evidence of guilt or innocence of a defendant by the prosecution even if it is favourable to the defense. Brady v. Maryland is considered to be a landmark case as it represents the so-called “Brady Rule”, which requires disclosing any material by the prosecution, providing exculpatory evidence upon request (Brady v. Maryland, 373 U.S. 83 (1963)).

• Giglio v. United States, 405 U.S. 150 (1972)

In this case, both Giglio and Taliento were suspected of forgery. Taliento was offered to receive immunity by the prosecution if he agreed to provide testimony against Giglio. During the trial procedure, Taliento claimed that he was not offered leniency for his testimony against Giglio. After two years, the trial was handed to another prosecutor who did not consider Taliento’s testimony. Giglio was convicted of forgery and sentenced to five years’ imprisonment. Giglio appealed when he learned of immunity given to Taliento. The key issue was if the prosecution’s failure to disclose a witness’s promise of immunity was a ground for conducting a new trial. The US Supreme Court granted certiorari in order to decide if there was a need for turning over the evidence as a matter of due process under Brady v. Maryland (Giglio v. United States, 405 U.S. 150 (1972)).

• United States v. Agurs, 427 U.S. 97 (1976)

In this case, Agurs was convicted of murder. James Sewell was killed with a knife. Agurs and James Sewell registered at a hotel as intimate partners. Fifteen minutes later, hotel staff heard screaming for help. They found Agurs and James Sewell in struggle for possession of a knife. The James had serious wounds, while Agurs had no wounds. The hotel staff stopped the struggle and called the police. Agurs’ defense counsel argued that it was self-defence, but Agurs was  convicted of murder. A motion was filed some time later with the goal of conducting a new trial. The defense counsel found that James Sewell had a prior criminal record that could explain the act of violence. The prosecution did not disclose the obtained evidence to the defense. This type of evidence was admissible even if it was unknown to the defendant. The key issue was if the prosecution had duty to provide exculpatory evidence to the defense. The court reversed the conviction because the prosecution had no duty under the Due Process Clause to disclose exculpatory evidence which was absent in a pre-trial request for specific type of evidence. The prosecutor did not voluntarily disclose the information related to the victim’s past experience, which included several offenses and carrying a deadly weapon; therefore, the defendant was not deprived of a fair trial as guaranteed by the Due Process Clause of the Fifth Amendment to the US Constitution (United States v. Agurs, 427 U.S. 97 (1976)).

References

Brady v. Maryland, 373 U.S. 83 (1963). Justia US Supreme Court. Retrieved from:<https://supreme.justia.com/cases/federal/us/373/83/case.html>

Giglio v. United States, 405 U.S. 150 (1972). Justia US Supreme Court. Retrieved from:<https://supreme.justia.com/cases/federal/us/405/150/case.html>

United States v. Agurs, 427 U.S. 97 (1976). Justia US Supreme Court. Retrieved from:<https://supreme.justia.com/cases/federal/us/427/97/case.html>

The terms offer and acceptance. (2016, May 17). Retrieved from

[Accessed: January 20, 2022]

"The terms offer and acceptance." freeessays.club, 17 May 2016.

[Accessed: January 20, 2022]

freeessays.club (2016) The terms offer and acceptance [Online].
Available at:

[Accessed: January 20, 2022]

"The terms offer and acceptance." freeessays.club, 17 May 2016

[Accessed: January 20, 2022]

"The terms offer and acceptance." freeessays.club, 17 May 2016

[Accessed: January 20, 2022]

"The terms offer and acceptance." freeessays.club, 17 May 2016

[Accessed: January 20, 2022]

"The terms offer and acceptance." freeessays.club, 17 May 2016

[Accessed: January 20, 2022]
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