Commonwealth v. Willis, 46 A.3d 648

At ~2:15 a.m. on April 29, 2005, Thomas was robbed by two men who brandished a gun and demanded money, about $40 given under threat.
Thomas later identified Willis as one of the robbers from photo arrays and a lineup, with trial testimony corroborating identification.
Willis was convicted November 1, 2006, of robbery and possession of an instrument of crime.
A Brady claim arose because a co-defendant, Peoples, allegedly implicated Woodard and claimed Willis was not the sole actor; the statement was omitted before trial.
The trial court ruled the statement inadmissible hearsay and not material; Superior Court remanded for a new trial based on Brady materiality.
This Court granted review to decide whether inadmissible, undisclosed evidence can be material under Brady and whether Green should be overruled.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Brady materiality standard for inadmissible evidence	Willis (plaintiff) argues Green allows inadmissible evidence to be material.	Commonwealth argues Wood/Green require admissibility or lack of materiality without adducible leads.	Materiality may extend to inadmissible evidence if it could lead to admissible evidence and shows a reasonable probability of different outcome.
Whether Green should be overruled	Willis urges overruling Green to align with Wood and Bagley.	Commonwealth urges maintaining Green as controlling law.	Court declines to overrule Green; Ly reaffirmed Green’s core principle that nondisclosed favorable evidence may be material.
Whether Peoples’ statement was material under Brady	Willis contends timely disclosure would have led to admissible evidence altering outcome.	Commonwealth claims no reasonable probability that disclosure would change trial result; testimony would be unavailable and Woodard not credible.	Willis failed to show a reasonable probability that disclosure would have changed the outcome; new-trial remand reversed.

Brady v. Maryland, 373 U.S. 83 (U.S. 1963) (establishes due process duty to disclose favorable evidence material to guilt/punishment)
Wood v. Bartholomew, 516 U.S. 1 (U.S. 1995) (admissibility may be prerequisite to materiality; nondisclosed inadmissible evidence generally not material unless leads to admissible evidence)
Bagley v. United States, 473 U.S. 667 (U.S. 1985) (materiality includes impeachment evidence; reasonable probability standard; helper on trial preparation considerations)
Agurs v. United States, 427 U.S. 97 (U.S. 1976) (establishes broad disclosure duty depending on circumstances; admissibility not strict gatekeeper for materiality)
Kyles v. Whitley, 514 U.S. 419 (U.S. 1995) (duty to learn favorable evidence; materiality requires reasonable probability of different outcome)
Commonwealth v. Green, 536 Pa. 599 (Pa. 1994) (extended Brady materiality to trial preparation in some contexts (Ly later cited))