Ashlei Lewis

Unit 1 Individual Project

CJUS440

May 20, 2021

Brady VS Maryland & Giglio VS United States:

Case Briefs, Relevant Evidence & Exculpatory Evidence:

 Brady VS Maryland:

A Maryland Jury found John L. Brady and his companion Charles Boblit guilty of

first-degree murder. Brady said that he participated in the robbery beforehand but had nothing to

do with the murder thereafter. During the trial, Brady was tried, convicted, and sentenced to

capital punishment. Brady then found out that the prosecution had withheld evidence that was

favorable to Brady and that it was therefore a denial of his 14th amendment right of due process

of the law. This evidence was Boblit’s confession to the murder which happened after the

robbery in which Brady held that he participated. When the case went to the Maryland Court of

Appeals, they held the decision of the lower court, but remanded it back for a new trial of

punishment only, and not the guilt aspect.

There were two major issues present in this case, the prosecution not using Boblit’s

murder confession and the Maryland Court of Appeals being questioned as to whether or not it

was wrong to remand the case to a lower court solely based upon the question of punishment and

not of guilt towards Brady in this case.

In a 7-2 vote headed by Justice William O. Douglas, the Supreme Court held that the

prosecution’s withholding of crucial evidence did, in fact, violate the 14th amendment Due

Process Clause of the Constitution, which in turn, affirmed the Maryland State Court’s decision.

The reason being that according to Maryland State Law, the confession from Brady’s companion,

Boblit, would not exonerate him from the murder, so a remand for only punishment was a proper

verdict by the Maryland Court of Appeals.

Justice Harlan was joined by Justice Black in Dissenting. Their argument is as follows:

“I think this case presents only a single federal question: did the order of the Maryland

Court of Appeals granting a new trial, limited to the issue of punishment, violate [the]
petitioner's Fourteenth Amendment right to equal protection? In my opinion, an affirmative

answer would be required if the Boblit statement would have been admissible on the issue of

guilt at [the] petitioner's original trial… The Court, however, holds that the Fourteenth

Amendment was not infringed because it considers the Court of Appeals' opinion, and the other

Maryland cases dealing with Maryland's constitutional provision making juries in criminal cases

'the Judges of Law, as well as of fact,' as establishing that the Boblit statement would not have

been admissible at the original trial on the issue of petitioner's guilt.”

Basically saying that they both disagree that Brady’s 14th amendment right to Due

Process of law wasn’t infringed upon and that Brady would have been convicted of committing

the murder regardless of Boblit’s confession being used in court or not.

Giglio VS United States:

John Giglio was tried and convicted of passing forged money orders. While his appeal to

the U.S. Court of Appeals in the Second Circuit was pending, Giglio’s counsel discovered new

evidence that indicated that the prosecution had completely failed to mention that it had

promised immunity to a key witness that had testified against Mr. Giglio at trial. The district

court then denied Giglio’s motion for a new trial finding that the error from the prosecution did

not affect the verdict whatsoever. The case was then taken to the Court of Appeals who affirmed

this judgment.

The issue at hand for this case is that the prosecution for this case promised a witness

immunity for testifying in court against the defendant Mr. Giglio, which should’ve warranted a

new trial for Mr. Giglio, but this did not happen until much later in the case.
 The U.S. Supreme Court then suddenly, unanimously reversed the decisions of the lower

courts and remanded Mr. Giglio’s case for a new trial. The reasoning behind this decision was

the Supreme Court held that the evidence of the agreement of immunity for the key witness was

relevant to the witness’s credibility. And because this new evidence affected the witness’s

credibility and because the prosecution relied so heavily upon this testimony for their case, the

original trial had violated the Due Process Clause of the 14th Amendment. Giglio was then

entitled to a new trial. Justices Powell and Rehnquist decided against participating in this verdict.

There were no Dissenting Opinions for this case.

Relevant evidence is defined as “evidence having any tendency to make the existence of

any fact that is one of consequence to the determination of the action more probable or less

probable than it would be without the evidence.” (tncourts, n.d.) This means that evidence can

only be relevant to a case if it is connected to the case in some way, or is brought to the attention

of anyone involved in the case and can be used to prove or disprove that something happened or

didn’t happen and that someone was or was not involved in the circumstances surrounding the

case itself.

Exculpatory evidence is “evidence such as a statement, tending to excuse, justify or

absolve the alleged fault or guilt of a defendant. But this evidence must be favorable to the

defendant in that it clears or tends to clear him or her of guilt.” (Cornell Law School, n.d.).

Meaning that evidence that is found and used in court to prove or disprove the innocence or guilt

of a person involved in or being accused of committing a crime, that is punishable by law, is

exculpatory evidence.
Sources:

Brady v. Maryland. (n.d.). Oyez. Retrieved May 17, 2021, from

https://www.oyez.org/cases/1962/490

Courts, T. S. (n.d.). Tennessee Administrative Office of the Courts. Retrieved May 18, 2021,

from https://www.tncourts.gov/rules/rules-evidence/401.

Giglio v. United States. (n.d.). Oyez. Retrieved May 17, 2021, from

https://www.oyez.org/cases/1971/70-29

Hooper, L. L., Marsh, J. E., & Yeh, B. (2004, October). Treatment of Brady v. Maryland Material

in United States District and State Courts' Rules, Orders, and Policies. US Courts.

Retrieved May 18, 2021, from

https://www.uscourts.gov/sites/default/files/bradymat_1.pdf.

School, C. L. (n.d.). John L. BRADY, Petitioner, v. STATE OF MARYLAND. Legal Information

Institute. Retrieved May 18, 2021, from

https://www.law.cornell.edu/supremecourt/text/373/83.