CASES ADJUDGED
IN THE
SUPREME COURT OF THE UNITED STATES
AT
OCTOBER TERM, 1995
on petition for writ of certiorari to the united states court of appeals for the ninth circuit
No. 94-1419. Decided October 10, 1995
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
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