United States v. Agurs case brief

United States v. Agurs case brief summary
427 U.S. 97 (1976)

CASE SYNOPSIS

The United States appealed a judgment of the United States Court of Appeals for the District of Columbia Circuit that reversed defendant's murder conviction on the ground that the prosecutor's failure to disclose the victim's prior criminal record violated the Due Process Clause.

CASE FACTS
Defendant was convicted of murdering a man by stabbing him with his own knife. Defense counsel made no discovery request of the prosecutor. The prosecutor failed to voluntarily disclose the victim's past criminal record, which included offenses for assault and carrying a deadly weapon.

DISCUSSION

• The court reversed a lower court's reversal of defendant's murder conviction because the prosecutor had no duty, under the Due Process Clause of U.S. Constitutional Amendment V, to voluntarily disclose exculpatory matter absent a pretrial request for specific evidence. 
• In the context of the entire record the omitted evidence was not "material," i.e. it did not create a reasonable doubt that did not otherwise exist. 
• The court held that the trial court employed the proper standard of "materiality," considered the omitted evidence in the context of the entire record, and properly ruled that the evidence supported a finding that defendant was guilty beyond a reasonable doubt. 
• Therefore, the prosecutor's failure to tender the evidence to the defense did not deprive defendant of a fair trial as guaranteed by the Due Process Clause.

CONCLUSION
The court reversed a lower court's reversal of defendant's murder conviction because the prosecutor had no duty under the Due Process Clause of the Fifth Amendment to voluntarily disclose exculpatory matter absent a pretrial request for specific evidence.



Recommended Supplements for Criminal Procedure Criminal Procedure: Examples & Explanations, Sixth Edition
Emanuel Law Outline: Criminal Procedure