Wood v. Bartholomew

LOCATION:Virginia Military Institute

DOCKET NO.: 94-1419
DECIDED BY: Rehnquist Court (1986-2005)
LOWER COURT: United States Court of Appeals for the Ninth Circuit

CITATION: 516 US 1 (1995)
DECIDED: Oct 10, 1995

Facts of the case

Dwayne Bartholomew was convicted in a Washington state court of murder during a robbery. Bartholomew admitted the robbery, but claimed the victim was killed accidentally. At trial, Bartholomew’s brother Rodney testified that Bartholomew had told them of his robbery plans and his intent to leave no witnesses. The prosecution never disclosed that Rodney’s responses to questions about the robbery and murder weapon, during a pretrial polygraph examination, indicated deception. Bartholomew filed for federal habeas, claiming that because the polygraph results were material under Brady v. Maryland, 373 U.S. 83, which provides that under the due process clause of the Fourteenth Amendment a state prosecutor is required to disclose material evidence favorable to an accused, the prosecution’s failure to disclose them justified setting aside the conviction. The District Court denied the writ. In reversing, the Court of Appeals concluded that the polygraph results, although inadmissible under Washington law, were material under Brady because they may have given Bartholomew’s counsel known of the results a stronger reason to investigate Rodney’s story.


Did a Court of Appeals err in concluding, in habeas corpus proceedings, that the prosecution’s failure to disclose to the accused the inadmissible results of a polygraph test of a witness violated due process?