Kyles v. Whitley
Encyclopedia
Kyles v. Whitley, , is a United States Supreme Court case that held that a prosecutor
has an affirmative duty to disclose evidence favorable to a defendant
.
held that the suppression by the prosecution of evidence favorable to an accused upon request violates due process where the evidence is material either to guilt or to punishment, irrespective of the good faith or bad faith of the prosecution. The court also discussed United States v. Bagley and the reasonable probability of a different result standard. “The question is not whether the defendant would more likely than not have received a different verdict with the evidence, but whether in its absence he received a fair trial, understood as a trial resulting in a verdict worthy of confidence.” It noted that this test was not a sufficiency of the evidence test. “A defendant need not demonstrate that after discounting the inculpatory evidence in light of the undisclosed evidence, there would not have been enough left to convict. Finally, they noted that the evidence must be considered on a whole, not piece by piece. Ultimately they found that based on the evidence that was not brought to light, a reasonable juror could have found Kyles not guilty.
Prosecutor
The prosecutor is the chief legal representative of the prosecution in countries with either the common law adversarial system, or the civil law inquisitorial system...
has an affirmative duty to disclose evidence favorable to a defendant
Defendant
A defendant or defender is any party who is required to answer the complaint of a plaintiff or pursuer in a civil lawsuit before a court, or any party who has been formally charged or accused of violating a criminal statute...
.
Background
Kyles was convicted of murder. Beanie was the main person who originally inculpated Kyles even though later there were many eye witnesses who identified Kyles as the murderer. The police/state never disclosed to the defense inconsistent statements made by Beanie, statements made by Beanie where he incriminated himself, inconsistent descriptions made by the eye witnesses, and several other pieces of potentially exculpatory evidence.Opinion of the Court
The Court held that Kyles should be granted a new trial. The Court noted that Brady v. MarylandBrady v. Maryland
Brady v. Maryland, 373 U.S. 83 , was a United States Supreme Court case in which the prosecution had withheld from the criminal defendant certain evidence. The defendant challenged his conviction, arguing it had been contrary to the Due Process Clause of the Fourteenth Amendment to the United...
held that the suppression by the prosecution of evidence favorable to an accused upon request violates due process where the evidence is material either to guilt or to punishment, irrespective of the good faith or bad faith of the prosecution. The court also discussed United States v. Bagley and the reasonable probability of a different result standard. “The question is not whether the defendant would more likely than not have received a different verdict with the evidence, but whether in its absence he received a fair trial, understood as a trial resulting in a verdict worthy of confidence.” It noted that this test was not a sufficiency of the evidence test. “A defendant need not demonstrate that after discounting the inculpatory evidence in light of the undisclosed evidence, there would not have been enough left to convict. Finally, they noted that the evidence must be considered on a whole, not piece by piece. Ultimately they found that based on the evidence that was not brought to light, a reasonable juror could have found Kyles not guilty.
See also
- List of United States Supreme Court cases, volume 514
- List of United States Supreme Court cases
- Lists of United States Supreme Court cases by volume
- List of United States Supreme Court cases by the Rehnquist Court