Bracy v. Gramley

Bracy (defendant) was tried, convicted and sentenced to death before then-Judge Maloney, who himself was later convicted of conspiracy, racketeering, extortion, and obstructing justice in April 1993. Maloney had a long history of corrupt behavior, with numerous contacts to organized crime. Four months after Maloney’s conviction, Bracy filed a habeas corpus petition, claiming that he was denied a fair trial, since, “in order to cover up the fact that [Maloney] accepted bribes from defendants in some cases, [Maloney] was prosecution oriented in other cases.” That is, in order to camoflage his practice of taking bribes from defendants, sometimes Maloney, tilting the other way, went out of his way to favor the prosecution. Bracy alleges that this happened in his case. Bracy wanted to obtain discovery to support his claim. The district court denied both Bracy’s fair-trial claim and discovery request, saying that his allegations “contain insufficient specificity or good cause to justify further discovery.” The court of appeals affirmed, though the vote was divided. It said that Bracy had not shown “good cause” for discovery to prove his claim, pursuant to Habeas Corpus Rule 6(a). In the court’s view, even if Bracy found evidence that Maloney was biased against defendants who did not bribe him, it would not prove that he was biased in Bracy’s particular case. The United States Supreme Court granted certiorari.