Facts
- Hughes Anderson Bagley was indicted in the Western District of Washington on federal narcotics and firearms charges arising from an undercover investigation.
- The government’s principal witnesses were two private security guards who assisted ATF and testified at Bagley’s bench trial.
- Before trial, Bagley sought discovery of any deals, promises, or inducements offered to government witnesses for their testimony.
- The government did not disclose that the witnesses had signed ATF contracts providing for payment commensurate with information supplied (with contemplated payments of about $300 each).
- The trial judge convicted Bagley on narcotics counts and acquitted him on firearms counts.
- Years later, Bagley obtained the payment-contract forms and sought postconviction relief under 28 U.S.C. § 2255, arguing the nondisclosure deprived him of impeachment material showing witness bias.
Issues
- Whether nondisclosure of requested impeachment evidence about payments to key government witnesses requires automatic reversal.
- What materiality standard governs suppressed impeachment evidence under due process principles applicable to prosecution disclosure obligations.
Decision
- The Supreme Court reversed the court of appeals and rejected any rule requiring automatic reversal for nondisclosure of impeachment evidence.
- The Court held that impeachment evidence is “favorable” evidence subject to disclosure obligations.
- Relief is required only if the suppressed evidence is material: there is a reasonable probability that disclosure would have produced a different result, sufficient to undermine confidence in the outcome.
- The case was remanded for application of that materiality standard to the undisclosed payment contracts.
Legal Principles
- Impeachment evidence, including evidence of payments or inducements to government witnesses, qualifies as favorable evidence subject to constitutional disclosure requirements.
- A single materiality standard applies to suppressed favorable evidence (exculpatory or impeachment), without different tests based on whether the defense made a specific or general request.
- Suppressed evidence is material only if there is a reasonable probability that, had it been disclosed, the result of the proceeding would have been different.
- A “reasonable probability” is one sufficient to undermine confidence in the verdict; the defendant need not show it is more likely than not that the outcome would have changed.
- Nondisclosure that affects cross-examination does not require automatic reversal; it is assessed under the same materiality standard.
Conclusion
The Court held that suppression of impeachment evidence warrants relief only when it is material under the reasonable-probability/undermines-confidence standard, and it remanded for the lower court to determine whether the undisclosed witness-payment contracts met that threshold.