United States v. Bagley Case Brief

Why is the case important?

Upon realizing that the government did not disclose impeachment evidence, Bagley brought a motion to vacate his sentence wherein he was found guilty on federal narcotics charges.

Facts of the case

“In October 1977, Hughes Anderson Bagley was indicted on fifteen charges of violating federal narcotics and firearms statutes. The government’s two principal witnesses were James F. O’Connor and Donald E. Mitchell, private security guards. Between April and June 1977, they assisted the Bureau of Alcohol, Tobacco, and Firearms (“ATF”) in conducting an undercover investigation of Bagley. In response to a discovery request for information about any deals, promises or inducements made to O’Connor or Mitchell, the government produced only affidavits from each man stating that each spoke without any threats or rewards, or promises of reward. Bagley waived his right to a jury trial. At trial, O’Connor and Mitchell testified about the firearms and narcotics charges. On December 23, 1977, the court found Bagley guilty on the narcotics charges, but not the firearms charges.In mid-1980, Bagley filed requests pursuant to the Freedom of Information Act and to the Privacy Act of 1974. He received copies of ATF form contracts, each entitled, “Contract for Purchase of Information and Payment of Lump Sum Therefor.” These contracts indicated that O’Connor and Mitchell provided information to the ATF and promised a future payment of $300 to each informer. Bagley moved to vacate his sentence under 28 U.S.C. § 2255, alleging that the government’s failure to disclose the contracts violated his right to due process under the Fourteenth Amendment.The motion came before the same district judge who presided at Bagley’s trial. At an evidentiary hearing, a magistrate found that neither informant expected payment for his testimony. In contrast, the district judge found that O’Connor and Mitchell probably expected to receive compensation for their assistance, and that the government suppressed evidence favorable to Bagley. He also concluded, however, that the disclosure would not have had an effect on the court’s verdict. He emphasized that Bagley’s counsel did not seek to discredit O’Connor or Mitchell on cross-examination. The United States Court of Appeals, Ninth Circuit, reversed, reasoning that the government’s failure to disclose required automatic reversal because it impaired Bagley’s Sixth Amendment right to confront adverse witnesses through effective cross-examination.”

Question

Whether failure to provide impeachment evidence to a defendant, when it has been requested through discovery, is reversible error.

Answer

Remanded. In an opinion for the court, Justice Blackmun wrote that it is not necessarily reversible error, and in order to determine whether a sentence should be vacated, the court has a duty to determine whether the failure to disclose said evidence would affect the immediate outcome of the case. Justice Blackmun also gave weight to the fact that a specific defense request for information had been ignored.

Conclusion

The United States Supreme Court reversed the decision of the appellate court, and remanded the case for further proceedings. The Court held that prosecutor’s failure to assist a defendant by disclosing evidence that might be helpful in conducting cross-examination was a constitutional error only if the evidence was material in the sense that its suppression might have affected the outcome of the trial. According to the Court, the non-disclosed evidence at issue was material only if there was a reasonable probability that, had the evidence been disclosed to the defense, the result of the proceeding would have been different.

  • Case Brief: 1985
  • Petitioner: United States
  • Respondent: Hughes Anderson Bagley
  • Decided by: Burger Court

Citation: 473 US 667 (1985)
Argued: Mar 20, 1985
Decided: Jul 2, 1985
Granted Nov 13, 1984