Kyles v. Whitley

In Kyles v. Whitley (1995) 514 U.S. 419, the United States Supreme Court emphasized that the focus of Brady materiality is on the outcome of the trial, the fairness of the trial, and whether the undisclosed evidence undermines confidence in the verdict: "The question is not whether the defendant would more likely than not have received a different verdict with the evidence, but whether in its absence he received a fair trial, understood as a trial resulting in a verdict worthy of confidence. A 'reasonable probability' of a different result is accordingly shown when the government's evidentiary suppression 'undermines confidence in the outcome of the trial.' " (Kyles, supra, 514 U.S. at p. 434) The Supreme Court upheld the materiality standards in United States v. Bagley and refined the respective duties of a prosecutor to disclose evidence under Brady v. Maryland in determining whether evidence was indeed suppressed. The court held that a prosecutor has a duty to learn of any favorable evidence known to others acting on the government's behalf in the case, which includes police. Id. at 437, 115 S. Ct. at 1567. But where a prosecutor fails to disclose known favorable evidence that rises to a level of material importance, the prosecutor has failed to meet their obligation under Brady. Id. at 438, 115 S. Ct. at 1568. The United States Supreme Court held that the materiality of the undisclosed evidence is determined by asking if there is a reasonable probability that, had the evidence been disclosed to the defense, the result of the proceeding would have been different. The Court elaborated by stating that "the question is not whether the defendant would more likely than not have received a different verdict with the evidence, but whether in its absence he received a fair trial, understood as a trial resulting in a verdict worthy of confidence." Id.