The cumulative effect of the prosecution’s withholding of evidence was insufficient to undermine confidence in the jury’s murder verdicts under Brady v. Maryland (1963) 373 U.S. 83. A large group of defendants were convicted of kidnapping, robbing, and beating a woman to death. Long after their convictions became final, defendants discovered that the prosecution possessed certain evidence that it had failed to disclose to the defense at the time of trial. In part, this included evidence that several men were seen running from the alley where the killing occurred and that one of them had been arrested for beating and robbing women. Impeachment evidence had also been withheld. In postconviction proceedings, defendants argued the evidence was favorable to the defense and material to their guilt or innocence, entitling them to relief under Brady. After hearings on defendants’ petitions the lower court affirmed the convictions. Certiorari was granted. Held: Affirmed. “Evidence is material within the meaning of Brady when there is a reasonable probability that, had the evidence been disclosed, the result of the proceedings would have been different.” A “reasonable probability” of a different result is one in which the suppressed evidence undermines confidence in the outcome of the proceedings. In order to make this determination, the withheld evidence must be evaluated in the context of the entire record. Here, defendants argued that the suppressed evidence would have provided them with an alternative defense; i.e., that the killing was not the result of a group attack but the work of several individuals. However, the withheld evidence was too little, too weak, and too distant from the main evidentiary points in this case to meet Brady’s materiality standards. The cornerstone of the prosecution’s case was a large group beating, which was attested to by virtually every witness. Several of the group perpetrators confessed and turned states’ evidence. The undisclosed impeachment evidence was cumulative to other impeachment evidence the defense already had at trial and was also insufficient to “undermine confidence” in the jury’s verdict.
The full opinion is available on the court’s website here: https://www.supremecourt.gov/opinions/16pdf/15-1503_4357.pdf