Student presentation of Brady v. Maryland (1963)

1. Brady v. Maryland (1963)
By: Clara Martinez,
Daniel Cutting

2. BRADY v. MARYLAND,
373 U.S. 83 (1963)

3. Brady v. Maryland
Argued: March 18th and 19th, 1963
Decided: May 13th, 1963

4. CASE SUMMARY
CITATION: Brady v. Maryland, 373 U.S. 83 (1963)
Argued: March 18, 1963
Type of case: CAPITAL PUNISHMENT FOR FIRST DEGREE MURDER
ISSUE: Disclosure of Exculpatory Evidence under Due Process Clause of 14th
Amendment (U.S. Constitution, Bill of Rights)
HOLDING: Affirmed.
RATIONALE: Suppression of co-defendant’s murder confession during trial violated
Brady’s right to due process under the 14th Amendment
Decided: May 13, 1963

5. U.S.
Constitutional
Right to Due
Process
The 5th Amendment and 14th
Amendment each contain a due
process clause.

6. U.S. Constitutional Right to Due
Process

7. Constitutional
Right to Due
Process
Reiterated in
the 14th
Amendment

8. BRADY v.
Maryland, 373
U.S. 83 (1963)

9. Important People:
John Leo Brady:
→ 24 years old
→ Grew up in Southern Maryland
→ Raised by Grandparents/Aunt
→ Suffered from otitis media
→ Served as a military policemen
until otitis media stopped
→ Returned to Maryland for work
in tobacco company
Donald Boblit:
→ 25 years old
→ Gawky, lonely, barely literate
Nancy Boblit:
→ Boblit’s Sister
→ Married to another man
→ Living with parents
→ Became pregnant by Brady

10. Factual Background
→ Brady wrote Nancy a $35,000 check on June 23, 1958
→ Brady planned to fund his $35,000 check with a bank
robbery
→ Brady didn’t have a car fast enough for a getaway
→ William Brooks had a new 1958 Ford Fairlane
→ Brady and Boblit conspired to ‘kidnap’ Brooks and use his
Fairlane

11. FACTUAL
BACKGROUND
→ Brady and Boblit ambushed Brooks as he
drove in his Ford Fairlane
→ Boblit jumped out from the woods with a
shotgun
→ Boblit knocked Brooks unconscious
→ The pair proceeded to kidnap Brooks by
driving his Fairlane
→ The pair drove Brooks to a wooded area

12. Factual Background:
→ Once in the wooded area, Brooks woke up
from being unconscious
→ Boblit then strangled Brooks with his plaid
shirt
→ Brooks died by strangulation
→ Brady fled to Cuba
→ No bank robbery occurred

13. Factual Background:
→ Brady fled to Cuba
→ No bank robbery occurred
→ Nancy’s $35,000 check bounced
→ Brady turned himself in at the
Cuban U.S. Embassy

14. Crime and Sentencing:
→ Brady soon found himself in Miami
→ Brady confessed to the FBI
→ Brady was tried for murder before Boblit
→ Both men were found guilty of murder in the
first degree and sentenced to death
→ Both convictions were upheld by the
Maryland Court of Appeals

15. Co-Defendants John Brady and Donald Boblit as Suspects,
Maryland State Court Jurisdiction, 1958

16. PROCEDURAL HISTORY
• June 27, 1958 – Murder of William Brooks
• July 9, 1958 – Boblit confession to the
actual murder while under custodial
interrogation
• Brady and Boblit found guilty of murder in
the first degree and sentenced to death in
separate trials.
• Brady was tried before Boblit.

17. PROCEDURAL HISTORY
• Maryland Court of Appeals reopened Brady case
• New “confession” evidence was discovered by Brady’s
attorney
• October 11, 1961 – Maryland Court of Appeals ruling
Withholding of confession evidence during Brady trial
violated his due process rights under the 14th Amendment
• October 8, 1962 – Certiorari granted, U.S. Supreme Court
• May 13, 1963 – U.S. Supreme Court Affirmed ruling of
Maryland Court of Appeals

18. U.S. Supreme Court Holding
Justice William Douglas for the majority opinion
Judgment of Maryland Appellate Court: Affirmed
Brady v. Maryland, 373 U.S. 83, *86 (1963)
We agree with the Court of Appeals that suppression of this
confession was a violation of the Due Process Clause of the
Fourteenth Amendment.”
Brady v. Maryland, 373 U.S. 83, *87 (1963)
“We now hold that the suppression by the prosecution of the
evidence favorable to an accused upon request violates due
process where the evidence is material either to guilt or to
punishment…”
Brady v. Maryland, 373 U.S. 83, *88 (1963)
“Not without some doubt, we conclude that the withholding
of this particular confession of Boblit’s was prejudicial to the
defendant Brady.”

19. Impact on Brady’s Sentence
• U.S. Supreme Court opinion in Brady upheld the Appellate Court
opinion
• The ruling held Brady’s 14th Amendment due process rights were
violated by the non-disclosure of exculpatory evidence.
• The non-disclosure prejudiced his sentencing but not the
determination of his guilt. Brady v. Maryland, 373 U.S. 83, *91
(1963)
• Result: Brady was given a new hearing at state-level
• Result: Brady’s death sentence was lowed to life imprisonment
• Brady was ultimately released on parole and moved to Florida to
start a family

20. Legacy and
Impact on
Society
• Brady v. Maryland (1963) has become a
landmark U.S. Supreme Court case
• The word “Brady” has become ubiquitous
in law enforcement
• The word “Brady” has become adjoined
throughout law enforcement.
• Phrases have emerged like “Brady
Disclosure” in the release of evidence
• Brady is now associated with releasing
exculpatory evidence to the defense

21. Later Cases Have Narrowed Brady
Precedent
• United States v. Bagley, 43 U.S. 667 (1985)
narrowed the scope of Brady disclosures
• Bagley was decided by the U.S. Supreme
Court on July 2, 1985
• Under Bagley, suppressed evidence must be
exculpatory and material for a violation to
result in reversal of a criminal conviction

22. References
Brady v. Maryland, 373 U.S. 83 (1963)
Brady v. State, 226 Md. 422 (1961)
Dybdahl, Thomas L., “An Odd Almost Senseless Series of Events,” The Marshall Project: Nonprofit
Journalism about Criminal Justice. Pub: June 24, 2018.
https://www.themarshallproject.org/2018/06/24/an-odd-almost-senseless-series-of-events
Gershman, Bennett L., Reflections on Brady v. Maryland. Pace University: DigitalCommons@Pace.
Pace Law Faculty Publications. Pub: 2006
United States v. Bagley, 43 U.S. 667 (1985)

23. Brady v. Maryland (1963)
By: Clara Martinez,
Daniel Cutting