## Facts

- Linda Agurs and James Sewell checked into a Washington, D.C. hotel, registering as husband and wife; Sewell had two knives on his person.
- Roughly fifteen minutes later, hotel employees heard Agurs screaming and forced entry, finding Agurs and Sewell struggling over a knife.
- Sewell suffered multiple stab wounds and was pronounced dead at the hospital; Agurs had no knife wounds.
- The prosecution presented evidence undermining a pure self-defense theory, including testimony that Sewell carried substantial cash but none was found among his effects.
- Agurs claimed self-defense, asserting Sewell was the aggressor.
- After conviction for second-degree murder, the defense learned Sewell had prior guilty pleas for assault and carrying a deadly weapon (apparently a knife).
- The defense moved for a new trial, arguing the prosecution’s failure to disclose Sewell’s record violated due process under Brady.
- The district court denied relief as the evidence was not materially different from what the jury already knew; the court of appeals reversed; the Supreme Court granted review.

## Issues

1. Whether due process imposes a constitutional duty on prosecutors to disclose exculpatory evidence absent a specific defense request.
2. What “materiality” standard governs undisclosed exculpatory evidence when there is no specific request and no claim the prosecution used perjured testimony.
3. Whether the victim’s undisclosed criminal record was material such that nondisclosure denied Agurs a fair trial.

## Decision

- The Supreme Court reversed the court of appeals and reinstated the conviction.
- The Court held that nondisclosure violates due process only when the omission is sufficiently significant to deny the defendant a fair trial.
- In cases with no specific defense request and no perjury claim, evidence is constitutionally material only if, evaluated in light of the entire record, it creates a reasonable doubt that did not otherwise exist.
- The Court concluded Sewell’s criminal record was not material under that standard because it was largely cumulative of trial evidence showing Sewell was armed and the confrontation was violent.

## Legal Principles

- Brady’s disclosure duty is grounded in due process and the right to a fair trial, not a constitutional requirement of broad, open-file discovery.
- The Constitution does not require disclosure of all information that might influence a jury; the mere possibility that undisclosed evidence could have helped the defense does not establish constitutional materiality.
- Materiality depends on the context of the whole trial record; when there is no specific request and no perjury, suppressed evidence is material only if it would create a reasonable doubt that otherwise would not exist.
- Courts assessing materiality must consider the omitted evidence together with the evidence presented at trial, rather than in isolation.

## Conclusion

United States v. Agurs limited constitutional disclosure claims to omissions that undermine trial fairness, holding that when the defense made no specific request and there is no perjury, suppressed evidence warrants relief only if it would have created a reasonable doubt not otherwise present in the full record.


United States v. Agurs, 427 U.S. 97 (1976)