Opinion · Supreme Court of the United States

Wood v. Bartholomew

116 S. Ct. 7

Type
Opinion
Court
Supreme Court of the United States
Jurisdiction
Federal
Date
1995-10-10
Topic
general

holding that the failure of the prosecution to disclose that a witness had taken a polygraph test was not material under Brady where the parties agreed that the results of the test were inadmissible under state law | finding that evidence that is inadmissible under state law is not material for purposes of establishing a Brady violation | finding that polygraph results could not be considered Brady material when those results would not have been admissible under state law | finding that polygraph results were not evidence for Brady purposes because they were inadmissible under state law | holding evidence "material" under Brady only where there exists reasonable probability that, had the evidence been disclosed, the result of trial would have been different | noting that federal courts should not grant “habeas relief on the basis of little more than speculation with slight support” | stating that a federal court may not grant habeas relief “on the basis of little more than speculation with slight support.” | holding evidence barred under state law “could have no direct effect on the outcome of trial, because respondent could” not introduce the statements during trial | stating that a federal court may not grant habeas relief “on the basis of little more than speculation with slight support.” | finding that suppressed evidence was not “material” under Brady due, in part, to its inadmissibility at trial | stating that “mere speculation” is inconsistent with the applicable standards for determining if a due-process Brady violation has occurred | holding that an appellate court must point to specific admissible evidence that could be utilized, otherwise the conclusion that the disclosed inadmissible evidence might have led to some additional evidence “is based on mere speculation” and is not enough to sustain Brady materiality | noting that inadmissible polygraph, test was not “evidence” and therefore was not material | observing that undisclosed information was “inadmissible under state law, even for impeachment purposes” and, as a result, the information at issue “is not evidence at all” (internal quotation marks omitted) | finding that the state’s failure to disclose that a key witness had failed a lie detector test did not create a reasonable probability of a different trial outcome, since Washington state evidence law precluded the introduction of polygraph evidence at trial | holding no violation of Brady where prosecution failed to disclose witness interviews that would likely have been inadmissible at trial and were, therefore, "as a matter of law, 'immaterial' for Brady purposes" | reversing grant of habeas corpus relief where evidence withheld by prosecution was inadmissible; thus, disclosure not “reasonably likely” to have resulted in different outcome | explaining that setting aside a conviction because disclosure “might have led to some additional evidence that could have been utilized” amounts to “mere speculation, in violation of the standards [the Court has] established” | finding no Brady violation where suppressed evidence was inadmissible and petitioner could offer only speculation that disclosure would have led to admissible evidence | considering whether trial counsel would have prepared differently given the results, though ultimately concluding that disclosure would not have resulted in a different outcome | analyzing whether ' the undisclosed evidence "might have led [defendant's] counsel to conduct -additional discovery that might have led to some additional evidence that could have been utilized” | observing that arguments not developed on appeal are deemed waived | rejecting Brady claim where it was "based on mere speculation, in violation of the standards [the Court has] established' | noting petitioner’s own trial counsel testified that the suppressed evidence would not have 59 “affected the outcome of the case” | noting that reliance is not “justified” when, “under the circumstances, the facts should

Citator

Cited by
127 opinions