Sunday, November 3, 2013

United States v. Bagley case brief

United States v. Bagley case brief summary
473 U.S. 667 (1985)

The government sought review of an order of the United States Court of Appeals for the Ninth Circuit, which held that the government violated defendant's constitutional right to effective cross-examination on a finding that the government withheld information from discovery that trial witnesses were paid for testimony.


  • Defendant was indicted for violating federal narcotics and firearms statutes. 
  • Defendant filed a discovery motion regarding whether witnesses were paid to give testimony. 
  • The prosecutor failed to disclose that witnesses would be paid after testimony. 
  • Defendant was found guilty. 
  • Subsequently, defendant discovered that the witnesses had been paid, and he sought to vacate his sentences on the grounds that failure to disclose violated his right to due process and to impeach witnesses. 
  • The trial court denied defendant's motion to vacate, holding that impeachment evidence would not have affected the outcome of the trial. 
  • The appellate court reversed, holding that the denial of evidence was a violation of due process and defendant's right to confrontation. 
The Court reversed and remanded for a determination of whether the failure to disclose the evidence would have affected the trial outcome, thus comprising a constitutional error where such evidence was material.


The Court reversed the order and remanded for a determination of whether the prosecutor's withholding of evidence was material in that it would have affected the outcome of the trial.

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

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