Brady Vs. Maryland: The Laws Of Evidence

Sandra Wallace

Unit 1 Individual Project

CJUS 440-1704B-01

Professor Hudson

The Laws of Evidence

Title: Brady v. Maryland

Facts: Both Charles Boblit and John Brady were found guilty of first-degree murder and in turns sentenced to the death penalty in the sentencing phase in the state court of Anne Arundel County. Brady volunteered that he was involved in the robbery but did not involve himself in the homicide, he stated Boblit did act of killing. But since the prosecution kept the admittance Brady learned after sentencing that Boblit had confessed to the murder. On appeal, the Maryland Court of Appeals held that suppression of the confession denied Brady due process and remanded the case to reconsider the question of punishment

only. (Oyez.org)
Issue: Prosecution kept the written confession from Boblit which negatively impacted the decision of the level of punishment against Brady.

Which in turns clearly violated Brady’s due process.

Decision: The prosecution had suppressed the evidence in the supreme court and the court held that it went against the Brady’s Due Process of the fourteenth Amendment right. The Court also stated that according to the Maryland state law, Boblit’s confession would not change or exonerate Brady, so the decision for reassessing Brady’s sentence was appropriate

Reasoning: If the evidence relates to the defendant’s guilt, innocence or sentencing, the Due Process clause requires the prosecution to turn over evidence that is favorable to the defense. (Legaldictionary.net) As far as due process is concerned, Brady was denied due process because he has the right to a fair trial. Prosecutors are not allowed false testimony to be presented nor are they allowed to go uncorrected if noticed.

Dissenting opinion: Brady’s due process was in fact violated by not bringing fourth the

confession.

Title: Giglio v. United States
Facts: Taliento and Giglio had been suspected of forging money orders with signatures and time and date stamps. Immunity was offered by Dipaola to Taliento for his testimony against Giglio, which he denied ever being offered. Giglio got five years in prison. Later Giglio found out about the immunity of Taliento. The Supreme Court granted certiorari to determine whether the evidence should have been turned over as a matter of due process under Brady v. Maryland, 373 U.S. 83 (1963). (Lets Ace Law School)
Issue: The government violated Giglio’s due process by not disclosing information and presenting Taliento’s testimony knowing it was false.

As far as the courts saw it, it was irrelevant. Withholding the information about the testimony is in violation of Giglio’s rights for due process. Since the testimony was announced alter, should it be considered new evidence?

Decision: The Supreme Court held that evidence of the agreement was relevant to the witness’ credibility. Because the new evidence affected the witness’ credibility and the prosecution’s case rested almost entirely on the witness’ testimony, the original trial violated due process and entitled Giglio to a new trial. (oyez.org) Since Taliento denied any immunity was offered to him and wasn’t corrected it discreated the evidence which was Taliento as a witness. Since the testimony was almost solely based off a witness Giglio definitely be given a new trial.

Reasoning: The responsibility of the prosecutor is to disclose information and evidence. If there is a promise being made by an attorney, then the information should be must be attributed to the government. The Supreme court had found that the prosecutor’s lacked to disclose evidence that was relevant to the defense. The prosecutor had also failed to correct the false evidence that had been presented at the

trial.
Dissenting opinions: Since Dipaola did not have authorization to make the promise to Taliento, the court stuck with their decision on not granting a retrial.

Relevant evidence – Evidence that is connected to the case in question. If the evidence has nothing to do with the case the evidence will be deemed inadmissible. For example, if the prosecution presents evidence pertaining to a robbery and the case in question is in regard to driving under the influence, then the evidence would be irrelevant.
Exculpatory evidence – exculpatory evidence is the evidence that usually proves that the defendant is not guilty. If the prosecution finds evidence that shows that the defendant did not commit the crime in question, the prosecution must hand it over to the defense. Consequences for not doing so, the case can possibly be dismissed, the case may be retried, or the person or people in question (defense) could possibly be found innocent.

References:

• {{meta.pageTitle}}. (n.d.). Retrieved November 20, 2017, from https://www.oyez.org/cases/1971/70-29
• Brady v. Maryland - Case Summary and Case Brief. (2017, April 16). Retrieved November 18, 2017, from https://legaldictionary.net/brady-v-maryland/
• Brady v. Maryland. (n.d.). Oyez. Retrieved November 21, 2017, from https://www.oyez.org/cases/1962/490
• Let's ace law school. (n.d.). Retrieved November 20, 2017, from https://www.quimbee.com/cases/giglio-v-united-states