The defendant and his companion, Boblit, were found guilty of murder in the first degree and were sentenced to death. Their trials were separate, with the defendant being tried first. At his trial, the defendant took the stand and admitted his participation in the crime, but he claimed that Boblit did the actual killing. The defendant’s counsel conceded that his client was guilty of murder in the first degree, asking only that the jury return that verdict “without capital punishment.” Prior to the trial, the defendant’s counsel had requested the prosecution to allow him to examine Boblit’s out-of-court statements. Several of those statements were shown to him; but one dated July 9, 1958, in which Boblit confessed to the actual homicide, was not provided to the defense and did not come to the defendant’s attention until after he had been tried, convicted, sentenced, and his conviction had been affirmed. The defendant requested a new trial based on the newly discovered evidence.
Whether the government’s failure to provide the companion’s confession to the defendant violated the Due Process Clause of the Fourteenth Amendment?
Yes. The government’s failure to provide evidence to the defendant that would have been useful to the defense violated the Due Process Clause of the Fourteenth Amendment.
Society wins not only when the guilty are convicted, but when criminal trials are fair. The administration of justice suffers when the accused are treated unfairly. A prosecution that withholds evidence from a defendant which would tend to exculpate him or reduce the penalty helps shape a trial that bears heavily on the defendant. Accordingly, the Court held the suppression by the prosecution of evidence favorable to an accused upon request violates due process where the evidence is material either to guilt or to punishment, irrespective of the good faith or bad faith of the prosecution.
373 U.S. 83; 83 S. Ct. 1194 (1963)