Brief Fact Summary. After being indicted for false representation, John Williams (respondent) filed a Motion for Disclosure of all exculpatory portions of the grand jury transcripts. Upon finding that the prosecution did not present this exculpatory evidence to the grand jury, respondent requested that his indictment be dismissed.
Synopsis of Rule of Law. There is no general rule requiring prosecutors to present exculpatory evidence.
Williams was accused of misrepresentation of his character, which was allegedly effected through two financial statements. The prosecutor did not present, however, evidence which showed that Williams was always candid with his financial information. After he was indicted, Williams sought to have that indictment overturned because the grand jury was not presented with all the information by the prosecutor. The District Court overturned the indictment and appeals ensued.
Issue. Whether a district court may dismiss an otherwise valid indictment because the Government failed to disclose to the grand jury exculpatory evidence.
Held. It is incumbent upon the defendant to present exculpatory evidence. Reversed.
Dissent. Points of Law - for Law School Success
It would run counter to the whole history of the grand jury institution, in which laymen conduct their inquiries unfettered by technical rules. View Full Point of Law
Justice Stevens, in his dissent, maintained that the Court has recognized that it has the authority to create and enforce limited rules applicable to grand jury proceedings, and the court should instill such rules in order to handle prosecutorial misconduct. Discussion.
When a defendant seeks to overturn an indictment, he must bear the burden of proving his own argument.