exculpatory evidence

Turner v. United States

Issues

What standard applies to the materiality of evidence withheld from criminal defendants by the government in order to assess whether a due process violation occurred, and should that standard differ based on the strength of the government’s case?

Court below

United States Court of Appeals for the D.C. Circuit

This case will address whether certain undisclosed evidence falls under the standard for prosecutorial disclosures as described by Brady v. Maryland, 373 U.S. 83 (1963). The defendants, Russell Overton and Charles Turner, were convicted of a murder that occurred in 1984 and contend that several pieces of evidence were improperly withheld by the prosecution, resulting in a violation of their Fifth Amendment right to due process. The United States asserts that the evidence in question does not fall within the scope of the Brady standard, and therefore no post-conviction relief is required. The outcome of this case will further articulate the standards of materiality, favorability, and suppression under Brady and elucidate what information a criminal defendant has a constitutional right to know before trial.

Questions as Framed for the Court by the Parties

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

Christopher and Charles Turner, Clifton Yarborough, Kevin Smith, Levy Rouse, and Timothy Catlett were convicted for the 1984 murder of Catherine Fuller. Turner v. United States, Nos. 12-CO-1362, 12-CO-1538, 12-CO1539, 12-CO-1540, 12-CO-1541, 12-CO-1542 & 12-CO-1543, at 14 (D.C. Cir. June 11, 2015).