Facts of the Case
A Maryland jury found John Brady and Charles Boblit guilty of first-degree murder in the state Circuit Court of Anne Arundel County. Brady maintained that he participated in the preceding robbery, but not in the killing. At sentencing, both men received the death penalty. After trial, Brady learned that Boblit previously confessed to the murder, but the prosecution suppressed that evidence for Brady’s trial. On appeal, the Maryland Court of Appeals held that suppression of the confession denied Brady due process and remanded the case to reconsider the question of punishment only.
Questions
Did the prosecution’s suppression of Boblit’s confession deny Brady due process?
Was the Maryland Court of Appeals wrong to remand only on the question of punishment?
Conclusions
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Yes, No. In a 7-2 decision, Justice William O. Douglas wrote the majority opinion affirming the state court. The Supreme Court held that the prosecution's suppression of evidence violated the Due Process Clause of the Fourteenth Amendment. The Court also held that according the Maryland state law, the confession would not exonerate Brady, so a remand only for reconsidering his punishment was proper.
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