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693 KB
Extraction Summary
8
People
3
Organizations
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Locations
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Events
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Relationships
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Quotes
Document Information
Type:
Legal document
File Size:
693 KB
Summary
This document is a legal argument from a court filing dated April 24, 2020. It outlines the Government's legal obligation under the Due Process Clause, as established by the landmark cases Brady v. Maryland and Giglio v. United States, to disclose material exculpatory and impeachment evidence to the defense. The text defines what constitutes "material" evidence and discusses legal precedents that clarify the scope and limitations of this disclosure requirement.
People (8)
| Name | Role | Context |
|---|---|---|
| Brady |
Party in the legal case Brady v. Maryland, which established a rule for disclosing exculpatory evidence.
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| Giglio |
Party in the legal case Giglio v. United States, related to the disclosure of impeaching evidence.
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| Coppa |
Party in the legal case United States v. Coppa.
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| Bagley |
Party in the legal case United States v. Bagley.
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| LeRoy |
Party in the legal case United States v. LeRoy.
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| Ruggiero |
Party in the legal case United States v. Ruggiero.
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| Payne |
Party in the legal case United States v. Payne.
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| Persico |
Party in the legal case United States v. Persico.
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Organizations (3)
| Name | Type | Context |
|---|---|---|
| The Government | government agency |
Referenced as the entity with an obligation to disclose exculpatory or impeaching evidence.
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| Second Circuit | court |
Cited as the court of appeals in several legal cases (2d Cir.).
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| DOJ | government agency |
Appears in the footer as part of a document identifier (DOJ-OGR-00022074).
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Timeline (1 events)
Locations (1)
| Location | Context |
|---|---|
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Mentioned in the case name Brady v. Maryland.
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Key Quotes (4)
"its suppression undermines confidence in the outcome of a trial."Source
— United States v. Bagley
(Defining when evidence is considered “material” for the purpose of disclosure obligations.)
DOJ-OGR-00022074.jpg
Quote #1
"The rationale underlying Brady is not to supply a defendant with all the evidence in the Government’s possession which might conceivably assist the preparation of his defense, but to assure that the defendant will not be denied access to exculpatory evidence only known to the Government."Source
— United States v. LeRoy
(Explaining the purpose and limits of the Brady disclosure rule.)
DOJ-OGR-00022074.jpg
Quote #2
"where the witness at issue supplied the only evidence linking the defendant(s) to the crime, or where the likely impact on the witness’s credibility would have undermined a critical element of the prosecution’s case."Source
— United States v. Payne
(Defining when impeachment evidence is considered material.)
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Quote #3
"where the undisclosed evidence merely furnishes an additional basis on which to challenge a witness whose credibility has already been shown to be questionable or is subject to extensive attack by reason of other evidence, the undisclosed evidence may properly be viewed as cumulative, and hence not material."Source
— United States v. Persico
(Explaining circumstances where undisclosed impeachment evidence is not considered material because it is cumulative.)
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Quote #4
Full Extracted Text
Complete text extracted from the document (2,024 characters)
Case 1:19-cr-00830-AT Document 35 Filed 04/24/20 Page 12 of 34
ARGUMENT
I. Applicable Law
A. Brady & Giglio
The Government has an obligation under the Due Process Clause to make a timely disclosure of any exculpatory or impeaching evidence that is material and in its possession. See Brady v. Maryland, 373 U.S. 83 (1963); Giglio v. United States, 405 U.S. 150 (1972); see also United States v. Coppa, 267 F.3d 132, 139-40 (2d Cir. 2001). Evidence is “material” in this sense only if “its suppression undermines confidence in the outcome of a trial.” United States v. Bagley, 473 U.S. 667, 678 (1985). “The rationale underlying Brady is not to supply a defendant with all the evidence in the Government’s possession which might conceivably assist the preparation of his defense, but to assure that the defendant will not be denied access to exculpatory evidence only known to the Government.” United States v. LeRoy, 687 F.2d 610, 619 (2d Cir. 1982) (citing United States v. Ruggiero, 472 F.2d 599, 604 (2d Cir. 1973)).
Impeachment evidence is material only “where the witness at issue supplied the only evidence linking the defendant(s) to the crime, or where the likely impact on the witness’s credibility would have undermined a critical element of the prosecution’s case.” United States v. Payne, 63 F.3d 1200, 1210 (2d Cir. 1995) (internal quotation marks and citations omitted). Similarly, “where the undisclosed evidence merely furnishes an additional basis on which to challenge a witness whose credibility has already been shown to be questionable or is subject to extensive attack by reason of other evidence, the undisclosed evidence may properly be viewed as cumulative, and hence not material.” United States v. Persico, 645 F.3d 85, 111 (2d Cir. 2011) (citing cases). With regard to the timing of disclosing material under Giglio, the Second Circuit, in Coppa, rejected the argument that such material should be disclosed when defendants make a
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