Brief Fact Summary. Upon realizing that the government did not disclose impeachment evidence, Bagley brought a motion to vacate his sentence wherein he was found guilty on federal narcotics charges.
Synopsis of Rule of Law. In deciding whether to vacate a sentence on the grounds that impeachment evidence was not provided to the defense, a court must make a determination of whether the outcome of the case would have been different.
We held that the government's failure to provide requested Brady information to Bagley so that he could effectively cross-examine two important government witnesses requires an automatic reversal.View Full Point of Law
Issue. Whether failure to provide impeachment evidence to a defendant, when it has been requested through discovery, is reversible error.
Held. Remanded. In an opinion for the court, Justice Blackmun wrote that it is not necessarily reversible error, and in order to determine whether a sentence should be vacated, the court has a duty to determine whether the failure to disclose said evidence would affect the immediate outcome of the case. Justice Blackmun also gave weight to the fact that a specific defense request for information had been ignored.
Dissent. Justices Marshall and Stevens both wrote dissents, maintaining that suppression, in response to a request for specific evidence is far more serious than nondisclosure of evidence. Additionally, Justice Marshall, notes that the prosecutor should bear the burden of proving the evidence had no harmful affect upon the defendant than vice versa.
Concurrence. Justice White concurred in the judgment, stating only that evidence is material only if there is a reasonable probability that it would have affected the result of the proceeding.
Discussion. While the majority seems to maintain that the prejudice to the defendant should be considered in determining whether suppression of evidence is harmful, it is also important to note that there this case shows there is a difference between deliberate suppression and nondisclosure of evidence.