## Facts

- Catherine Fuller was found dead in Washington, D.C., in October 1984, having suffered severe blunt-force injuries and sexual assault.
- The investigation produced no physical evidence identifying perpetrators; the medical examiner could not determine whether one person or a group caused the injuries.
- Prosecutors pursued a theory that a group of youths set out to rob someone, chose Fuller, forced her into an alley, and attacked her.
- In 1985, Charles S. Turner and several co-defendants were tried in D.C. Superior Court for crimes related to Fuller’s kidnapping, robbery, and murder.
- The prosecution’s case relied heavily on cooperating witnesses Calvin Alston and Harry Bennett, who described a group attack and identified participants in exchange for leniency.
- The jury also saw a recorded statement by defendant Clifton Yarborough describing his participation in a group assault on Fuller.
- Other witnesses testified they heard robbery planning, saw Fuller selected and forced into the alley, and observed a “gang” attacking her and aspects of the sexual assault.
- The defense generally did not contest that a group killed Fuller; each defendant argued he was not part of the group.
- Years later, petitioners obtained undisclosed prosecution-file materials and alleged constitutional violations based on withheld evidence suggesting (i) a possible alternative perpetrator (including information about James McMillan and another reported individual) and (ii) information arguably supporting a single-attacker theory (including a passerby’s statement about a closed garage door and hearing groans).
- Petitioners also identified undisclosed impeachment information affecting three prosecution witnesses, including prior inconsistent statements and information about mental health and substance use.

## Issues

1. Whether the prosecution’s failure to disclose favorable evidence required vacatur under *Brady v. Maryland* because the evidence was material—i.e., whether there was a reasonable probability that disclosure would have changed the trial outcome.

## Decision

- The Supreme Court affirmed the judgment (6–2).
- The Court held that, even assuming the evidence was favorable and suppressed, it was not material under *Brady* when assessed in the context of the entire trial record.
- The Court concluded there was no reasonable probability that disclosure would have produced a different verdict.

## Legal Principles

- Suppressed evidence violates *Brady* only if it is material: there must be a reasonable probability that, had the evidence been disclosed, the result of the proceeding would have been different.
- Materiality is assessed in light of the entire record and the cumulative effect of all suppressed evidence, not by evaluating each item in isolation.
- Evidence is not material when it is too weak or too attenuated from the central proof at trial to undermine confidence in the verdict.
- Additional impeachment evidence is less likely to be material where it is largely cumulative of credibility attacks already presented to the jury.

## Conclusion

The Court held that the suppressed alternative-perpetrator, single-attacker, and impeachment evidence did not meet *Brady*’s materiality threshold when considered cumulatively against the trial record supporting a group attack, so the convictions were not set aside.


Turner v. United States, 137 S. Ct. 1885 (2017)