United States v. Williams case brief

United States v. Williams case brief summary
504 U.S. 36 (1992)

CASE SYNOPSIS

Petitioner United States challenged the judgment of the United States Court of Appeals for the Tenth Circuit, which dismissed respondent investor's indictment for making false statements to a bank because the prosecutor had failed to fulfill its obligation to present "substantial exculpatory evidence" to the grand jury.

CASE FACTS
Upon the investor's indictment for making false statements to a bank, he claimed that dismissal was warranted because the prosecutor failed to fulfill its obligation to present "substantial exculpatory evidence" to the grand jury. Although the government did not contest the issue in the case immediately at hand, the Court granted certiorari because it did so as a party to the recent proceeding upon which the lower courts relied for their resolution of the issue, and did not concede in the current case the correctness of that precedent.

DISCUSSION

• The Court reversed the dismissal holding that the rule requiring disclosure to the grand jury of "substantial exculpatory evidence" was not supported by the trial court's "supervisory power," because the grand jury was an institution over whose functioning the courts did not preside. 
• The Court found that the rule was inconsistent with the traditional function of the grand jury, which was to determine whether enough evidence existed to prosecute, not to allow the accused to put on a defense. 
• The Court refused to convert a non-existent duty of the grand jury itself into an obligation of the prosecutor.

CONCLUSION
The Court reversed the judgment of the court of appeals and remanded the cause for further proceedings consistent with the Court's opinion.



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