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Turner v. United States

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Supreme Court of the United States
Turner v. United States
Reference: 15-1503
Issue: Due process
Term: 2016
Important Dates
Argued: March 29, 2017
Decided: June 22, 2017
Outcome
District of Columbia Court of Appeals affirmed
Vote
6-2 to affirm
Majority
Chief Justice John G. Roberts • Anthony Kennedy • Clarence Thomas • Stephen Breyer • Samuel Alito • Sonia Sotomayor
Dissenting
Ruth Bader Ginsburg • Elena Kagan


Turner v. United States is a case argued during the October 2016 term of the U.S. Supreme Court. Argument in the case was held on March 29, 2017. The case came on a writ of certiorari to the District of Columbia Court of Appeals. The Supreme Court consolidated arguments in the case with arguments in Overton v. United States. On June 22, 2017, in an opinion by Justice Stephen Breyer, the court affirmed the judgment of the D.C. Court of Appeals. Justice Elena Kagan authored a dissenting opinion which was joined by Justice Ruth Bader Ginsburg.

In the case, the court held that the evidence withheld by government prosecutors in the case did not come within the standards of materiality required under the U.S. Supreme Court's decision in Brady v. Maryland such that a reasonable probability existed that, had the evidence been disclosed, the outcome of the trial would have been different.

HIGHLIGHTS
  • The case: Defendants convicted in a 1985 trial sought to have their convictions vacated. They alleged that prosecutors failed to disclose material evidence during their trial. Prosecutors are required to turn over evidence under obligations imposed by the U.S. Supreme Court's ruling in Brady v. Maryland.
  • The issue: Under Brady v. Maryland,, does the failure of prosecutors to disclose certain evidence mandate that the defendants' convictions must be vacated?
  • The outcome: On June 22, 2017, the court affirmed the judgment of the D.C. Court of Appeals.


    • In brief: The defendants in this case were convicted of several charges related to the murder of a woman in Washington, D.C. Years later, evidence surfaced that the defendants allege was required to be presented during discovery, but which prosecutors withheld. The men sought to vacate their convictions but a lower court judge denied the defendants' motions and an appellate panel of the District of Columbia Court of Appeals affirmed. The defendants petitioned the U.S. Supreme Court for relief, arguing that the prosecutors' failure to disclose certain evidence was in violation of the Supreme Court's ruling in Brady v. Maryland. Argument in the cases were held on March 29, 2017.

    You can review the lower court's opinion here.[1]

    Here are our pages on the consolidated case: Overton v. United States.

    Click on the tabs below to learn more about this Supreme Court case.

    Case

    Background

    This was one of two cases consolidated for argument. These cases addressed a prosecutor's obligations to disclose evidence under the U.S. Supreme Court's opinion in Brady v. Maryland.

    In 1984, a group of teenagers was convicted of sexually assaulting and murdering Catherine Fuller in an alley near her home in Washington, D.C. Prosecutors offered no physical evidence during a 1985 trial, but the defendants were convicted on eyewitness testimony. Some years later, in a lengthy report in The Washington Post, reporters turned up evidence that was not shared with defense counsel at the time of the trial. Included in the evidence that prosecutors did not turn over was a statement indicating that another man, James McMillan, may have committed the murder. In the period between Fuller's murder and the start of the trial, McMillan was arrested and later convicted on charges of robbing and assaulting several women in the neighborhood where Fuller lived. In 1992, McMillan was convicted of the sexual assault and murder of a woman who lived near where Fuller was killed. Additional discovery revealed that the prosecutors withheld evidence that some of the witnesses suggested only a few, and perhaps as few as one, individuals murdered Fuller; this was counter to the prosecution's theory that Fuller was murdered by a large group.

    Overton and Turner sought to vacate their convictions, but a motions judge in the District of Columbia denied their motions. That decision was affirmed by the District of Columbia Court of Appeals. In their opinion, the appellate judges evaluated the claim that the government violated its obligations under the U.S. Supreme Court's ruling in Brady v. Maryland. In Brady, the Supreme Court ruled that the Fifth Amendment requires prosecutors to disclose, upon request, any material evidence that is favorable to an accused person. Failure to disclose this evidence is a violation of due process. There is no good faith exception to the Brady ruling. The panel noted that the primary and dispositive question for all of the Brady claims made in this case was whether or not the evidence withheld by the prosecution was material. According to the appellate panel's opinion,[1]

    “

    Evidence is material within the meaning of Brady 'if there is a reasonable probability that, had the evidence been disclosed to the defense, the result of the proceeding would have been different.' Materiality is 'not a sufficiency of the evidence test.' Rather, evidence is material if it 'could reasonably be taken to put the whole case in such a different light as to undermine confidence in the verdict.' Brady materiality must be assessed in terms of the cumulative effect of all suppressed evidence favorable to the defense, not on the evidence considered item by item. The cumulative effect of a collection of suppressed evidence may undermine confidence in the outcome of the trial even where each piece of evidence, viewed in isolation, would be insufficient. Of course, just as the trial court did, '[w]e evaluate the tendency and force of the undisclosed evidence item by item; there is no other way. We evaluate its cumulative effect for purposes of materiality separately...' [2]

    		”

    Based on its own assessment, the court held that the withheld evidence was immaterial and the convictions should be upheld.

    Overton and Turner filed separate petitions for certiorari to the U.S. Supreme Court. Overton challenged the legal standard the appellate court used to review his appeal while Turner asked the court to weigh in on whether, in determining the significance of evidence, courts can consider information that comes to light after trial. The U.S. Department of Justice asked the Supreme Court not to hear the case, but the justices agreed to consolidate the appeals and hear arguments over whether the court's ruling in Brady required that the defendants' convictions be vacated.[1][3][4][5]

    Petitioners' challenge

    Russell Overton, Charles Turner, et al. the petitioners, challenged the holding of the District of Columbia Court of Appeals that their convictions should not be overturned based on the U.S. Supreme Court's ruling in Brady v. Maryland.

    Certiorari granted

    On June 10, 2016, Charles Turner et al., the petitioners, initiated proceedings in the Supreme Court of the United States in filing a petition for a writ of certiorari to the District of Columbia Court of Appeals. The U.S. Supreme Court granted Turner et al.'s certiorari request on December 14, 2016, limiting argument to the following question: "Whether the petitioners' convictions must be set aside under Brady v. Maryland, 373 U.S. 83 (1963)." The court consolidated the case with arguments in Overton v. United States. Arguments in these cases were held on March 29, 2017.[6]

    Arguments


    Question presented

    Question presented:

    "Whether the petitioners' convictions must be set aside under Brady v. Maryland, 373 U.S. 83 (1963)."[6]


    Audio

    • Audio of oral argument:[7]



    Transcript

    • Transcript of oral argument:[8]

    Outcome

    Decision

    On June 22, 2017, in an opinion by Justice Stephen Breyer, the court affirmed the judgment of the District of Columbia Court of Appeals. Justice Elena Kagan authored a dissenting opinion which was joined by Justice Ruth Bader Ginsburg.

    In the case, the court held that the evidence withheld by government prosecutors in the case did not come within the standards of materiality required under the U.S. Supreme Court's decision in Brady v. Maryland such that a reasonable probability existed that, had the evidence been disclosed, the outcome of the trial would have been different..[9]

    Opinion

    After a review of the factual and procedural record of the case, Justice Breyer outlined the requirements under Brady v. Maryland to prove that withheld evidence is material. Based on these requirements, Breyer held that the petitioners' claims did not meet this standard. He wrote,[9]

    “

    [E]vidence is ‘material’ within the meaning of Brady when there is a reasonable probability that, had the evidence been disclosed, the result of the proceeding would have been different. ... A ‘reasonable probability’ of a different result' is one in which the suppressed evidence ‘undermines confidence in the outcome of the trial.’ ... In other words, petitioners here are entitled to a new trial only if they 'establis[h] the prejudice necessary to satisfy the materiality inquiry.' ... Consequently, the issue before us here is legally simple but factually complex. We must examine the trial record, 'evaluat[e]' the withheld evidence 'in the context of the entire record,' ... and determine in light of that examination whether 'there is a reasonable probability that, had the evidence been disclosed, the result of the proceeding would have been different.' ... Considering the withheld evidence 'in the context of the entire record,' ... we conclude that it is too little, too weak, or too distant from the main evidentiary points to meet Brady’s standards.[2]

    		”

    As a result of the court's opinion, the judgment of the D.C. Court of Appeals was affirmed.

    Concurring opinions

    There were no concurring opinions filed in this case.

    Dissenting opinions

    Justice Elena Kagan authored a dissenting opinion which was joined by Justice Ruth Bader Ginsburg. In Justice Kagan's view, the evidence withheld by the government could have influenced the outcome of the trial. Accordingly, she dissented from the court's opinion.[9]

    The opinion


    Filings

    The U.S. Supreme Court grantedTurner's certiorari request on December 14, 2016.

    Merits filings

    Parties' briefs

    • Charles Turner et al., the petitioners, filed a merits brief on January 27, 2017.
    • The United States of America, the respondent, filed a merits brief on February 27, 2017.

    Amicus curiae briefs

    The following groups filed amicus curiae briefs in support of the petitioners in the consolidated cases:

    • Brief of the Center on Wrongful Convictions of Youth
    • Brief of the National Association of Criminal Defense Lawyers
    • Brief of the Texas Public Policy Foundation et al.
    • Brief of various former prosecutors

    Certiorari filings

    Parties' filings

    • Charles Turner et al., the petitioners, filed a petition for certiorari on June 10, 2016.
    • The United States of America, the respondent, filed a brief in opposition to certiorari on October 14, 2016, pursuant to three orders extending the time to fle.

    Amicus curiae filings

    The following groups filed amicus curiae briefs in support of granting certiorari:

    • Brief of the Innocence Project
    • Brief of various former prosecutors

    See also

    Footnotes

    1. ↑ 1.0 1.1 1.2 District of Columbia Court of Appeals, Charles S. Turner et al. v. United States, decided June 11, 2015
    2. ↑ 2.0 2.1 Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
    3. ↑ SCOTUSBlog.com, "Justices grant review in four new cases," December 14, 2016
    4. ↑ The New York Times, "Justices to hear cases on withheld evidence and bad advice," December 14, 2016
    5. ↑ National Constitution Center, "Court to clarify suspects' Brady rights," December 15, 2016
    6. ↑ 6.0 6.1 Supreme Court of the United States, Turner v. United States, December 14, 2016
    7. ↑ Supreme Court of the United States, Turner v. United States, argued March 29, 2017
    8. ↑ Supreme Court of the United States, Turner v. United States, argued March 29, 2017
    9. ↑ 9.0 9.1 9.2 Supreme Court of the United States, Turner v. United States, June 22, 2017
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