Giglio V Us Case Study

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

Facts:
Gigilio was convicted and sentenced to five years in prison for passing forged money orders at a local bank. Mr. Robert Taliento is the local bank teller, alleged co-conspirator, and the only witness linking the appellant to the crime. It was Taliento who supplied Giglio with the customer’s bank signature card and it was Taliento who cashed the forged money orders. During the trial defense counsel cross-examined Taliento in regards to him receiving prosecutorial leniency in exchange for his testimony. Both Taliento and the Government attorney denied that any such deal existed. It was only after the appellant was convicted and sentenced to prison did the evidence of Taliento’s deal come to light.

Issue:
Whether or not the Government is obligated to provide exculpatory evidence in the form of impeachable evidence regardless of their good or bad faith in a criminal trial.

Rules:
Nondisclosure by prosecution violates due process. Mooney v. Holohan, 294

U.S. 103, 112 (1935)

The favorable evidence suppressed by the State was sufficient to amount to denial of due process Pyle v. Kansas, 317 U.S. 213, 215-216 (1942)
Violation of the right to due process occurs when the prosecution either solicits false evidence or allows it to be introduced without being corrected. Napue v. Illinois, 360 U.S. 264 (1959)

An appellant has a right to a new trial when material evidence is suppressed regardless of the intention of the prosecution. Brady v. Maryland, 373 U.S.

Analysis:
The court maintained in Mooney v. Holohan and Plye v. Kansas that the government has a responsibility to its citizens to ensure justice is achieved and to not employ deceptive practices by admitting false evidence to be presented to the court and jury. Deception occurred in this case when the Government withheld exculpatory evidence from the defense in the form a non-prosecutorial deal offered to Taliento, the prosecution’s key witness. This witness was not only a key witness against the appellant, but he also happened to be the alleged co-conspirator and the only witness linking him to the crime.

The court continues with the case of Napue v.

Illinois, which follows the opinion regarding the introduction of false evidence to the court and jury as a deliberate deception but takes it one step further. Napue argues when the State allows false evidence to be heard in a case without it being corrected this too was an intentional deception. Taliento took the stand during the appellant’s trial and was questioned vigorously by defense counsel as to whether or not he would receive prosecutorial leniency in exchange for his testimony. Time after time Taliento refuted the allegation of the agreement only for the appellant to later discover this was indeed the case. The deal was discovered in the opposition affidavit penned by the first prosecutor on the case, as well as the affidavit filed by the United States Attorney. The court perceives the prosecutor’s office as one entity to which a deal made by one assistant would be attributed the office as a

whole.
The final case examined by the court was Brady v. Maryland; in this case, the court held a new trial is warranted when the Government suppressed material evidence regardless of the prosecution’s reliance. The trial attorney was not aware of the arrangement Taliento had with the State nor did it matter, the fact that significant information was omitted and the likelihood that this information would alter the outcome of the case, meant the appellant would be granted a new trial. The American Bar’s Standards for Criminal Justice states, “the reliability of a given witness may well be determinative of guilt or innocence,” the court had to consider the fact that Taliento’s credibility as a witness would be called into question because of the nature of the deal he made with the state. For these reasons stated above the court reversed and remanded the appellant’s case for a new trial.

Conclusion:
Yes, the court ruled the Government was obligated to provide exculpatory evidence in the form of impeachment evidence regardless of their good or bad faith in a criminal trial.