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Wood v. Bartholomew, 516 U.S. 1 (1995)
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General SummaryThis case is from a collection containing the full text of over 16,000 Supreme Court cases from 1793 to the present. The body of Supreme Court decisions are, effectively, the final interpretation of the Constitution. Only an amendment to the Constitution can permanently overturn an interpretation and this has happened only four times in American history.
Wood v. Bartholomew, 516 U.S. 1 (1995)
Wood v. Bartholomew No. 94-1419 Decided October 10, 1995 516 U.S. 1
ON PETITION FOR WRIT OF CERTIORARI TO THE
UNITED STATES COURT OF APPEALS FOR THE NINTH CIRCUIT
Syllabus
Respondent was convicted in a Washington state court of murder during a robbery. He admitted the robbery, but claimed the victim was killed accidentally. When both his brother Rodney and Rodney’s girlfriend testified that respondent had told them of his robbery plans and his intent to leave no witnesses, the defense suggested they were lying to downplay Rodney’s participation in the crime. The prosecution never disclosed that the two had taken pretrial polygraph examinations and that the examiner had concluded that Rodney’s responses to questions about the robbery and murder weapon indicated deception. Respondent later filed for federal habeas, claiming, inter alia, that, because the polygraph results were material under Brady v. Maryland, 373 U.S. 83, the prosecution’s failure to disclose them justified setting aside the conviction. The District Court denied the writ, but the Ninth Circuit reversed, concluding that the polygraph results, although inadmissible under Washington law, were material under Brady because, had respondent’s counsel known of the results, he would have had a stronger reason to investigate Rodney’s story and might have deposed Rodney and used the answers in Rodney’s cross-examination.
Held: the Ninth Circuit’s decision is a misapplication of this Court’s Brady jurisprudence. Evidence is material under Brady, and the failure to disclose it justifies setting aside a conviction, only where there exists a reasonable probability that, had the evidence been disclosed, the result at trial would have been different. The polygraph results were not evidence at all, and their disclosure would have had no direct effect on the trial’s outcome because respondent could have made no mention of them during argument or while questioning witnesses. The Ninth Circuit’s judgment is based on mere speculation that disclosure might have led respondent’s counsel to conduct additional discovery. Yet counsel’s trial strategy did not involve deposing Rodney, and counsel candidly acknowledged that disclosure would not have affected the scope of his cross-examination. Since the case against respondent was overwhelming, even without Rodney’s testimony, it should take more than supposition on respondent’s weak premises to undermine a court’s confidence in the trial’s outcome.
Certiorari granted; 34 F.3d 870, reversed and remanded.
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Chicago: U.S. Supreme Court, "Syllabus," Wood v. Bartholomew, 516 U.S. 1 (1995) in 516 U.S. 1 516 U.S. 2. Original Sources, accessed November 22, 2024, http://originalsources.com/Document.aspx?DocID=8TU9SCUSRTERXHM.
MLA: U.S. Supreme Court. "Syllabus." Wood v. Bartholomew, 516 U.S. 1 (1995), in 516 U.S. 1, page 516 U.S. 2. Original Sources. 22 Nov. 2024. http://originalsources.com/Document.aspx?DocID=8TU9SCUSRTERXHM.
Harvard: U.S. Supreme Court, 'Syllabus' in Wood v. Bartholomew, 516 U.S. 1 (1995). cited in 1995, 516 U.S. 1, pp.516 U.S. 2. Original Sources, retrieved 22 November 2024, from http://originalsources.com/Document.aspx?DocID=8TU9SCUSRTERXHM.
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