United States v. Bagley

473 U.S. 667 (1985)

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Nature of the Case

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Facts

Bagley (D) was indicted for violating federal narcotics and firearm statutes. D filed discovery motions looking to discover any deals the government had made with any witnesses to be called at trial. The government responded to the request with affidavits made by O'Connor and Mitchell two key witnesses recounting their undercover work for the ATF stating that they made all reports and statements freely without any threats or rewards, or promises of reward having been made by the government. D waived his right to a jury trial and was found guilty at trial on the narcotics charges but not the firearms charges. Under a freedom of information request, D eventually found that both O'Conner and Mitchell had been paid $300. D then moved to vacate his sentence. D alleged that P's failure to disclose the contracts, which he could have used to impeach O'Connor and Mitchell, violated his right to due process under Brady v. Maryland. The Magistrate found that the printed form contracts were blank when O'Connor and Mitchell signed them and were not signed by an ATF representative until after the trial. Following the trial and decision in respondent's case, ATF made payments of $300 to both O'Connor and Mitchell pursuant to the contracts. The District Court reasoned: almost all of the testimony of both witnesses was devoted to the firearms charges in the indictment. Respondent, however, was acquitted on those charges. The testimony of O'Connor and Mitchell concerning the narcotics charges was relatively very brief. The District Court concluded that the disclosure of the payment information would have had no effect on the outcome of the trial and that D was guilty of the offenses under which he had been convicted. The Ninth Circuit reversed on grounds that the government failed to disclose effective Brady information and inhibited effective cross-examination of two important government witnesses. The government appealed.