United States v. Bagley

United States Supreme Court473 U.S. 667 (1985)

Facts

Bagley (defendant) was indicted on drug and weapons charges. Before trial, Bagley sought discovery of the prosecution’s witnesses and any deals made in exchange for testimony. In response, the prosecution provided affidavits from two key witnesses stating that no deals had been made. The witnesses testified, and Bagley was convicted of the drugs charges and acquitted of the weapons charges. Later, Bagley filed Freedom of Information Act requests and received contracts that the two witnesses had signed agreeing to testify in exchange for $300. Bagley claimed that the government had violated his due process rights by withholding evidence that the defense could have utilized to impeach the witnesses. The district court held that the evidence was not material because the outcome would have been the same. The court of appeals reversed, holding that Bagley was entitled to automatic reversal under Brady v. Maryland, 373 U.S. 83 (1964). The United States Supreme Court granted certiorari.

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