Turner v. United States
137 S. Ct. 1885
| SCOTUS | 2017Background
- Seven defendants were convicted in D.C. for the 1984 kidnaping, robbery, sodomy, and murder of Catherine Fuller based primarily on testimony that she was attacked and killed by a large group.
- The prosecution’s core witnesses included two confessing participants (Alston and Bennett) who cooperated for leniency, several eyewitnesses who placed multiple defendants at the scene, and a recorded statement by petitioner Yarborough acknowledging participation in a group attack. Defendants did not testify.
- Years after convictions became final, petitioners discovered withheld government materials (Brady material) later turned over in postconviction proceedings.
- The withheld items at issue: (1) identity of James McMillan (one of two men seen in the alley after the body was found); (2) a statement by Willie Luchie who heard groans while passing the garage around 5:30–5:45 p.m.; (3) Ammie Davis interviews suggesting a different suspect (James Blue) but with credibility concerns; and (4) several prosecution notes tending to impeach eyewitnesses Eleby, Jacobs, Porter, and Maurice Thomas.
- The D.C. Superior Court held an extensive evidentiary hearing and concluded the withheld evidence was not material under Brady; the D.C. Court of Appeals affirmed. The Supreme Court also affirmed, holding there was no reasonable probability the suppressed evidence would have changed the trial outcome.
Issues
| Issue | Petitioners' Argument | Government's/Respondent's Argument | Held |
|---|---|---|---|
| Whether undisclosed evidence was "material" under Brady (i.e., reasonable probability of different result) | Withheld items (McMillan ID, Luchie’s groans, Davis statements, impeachment notes) were favorable and could have supported an alternative single-perpetrator theory or substantially impeached key witnesses, undermining the group-attack case | The withheld evidence was either weak, cumulative, or too remote from core proof of a group attack to create a reasonable probability of a different outcome | Affirmed: evidence not material; no reasonable probability outcome would differ when evaluated in context of entire record |
| Whether withheld impeachment information (about Eleby, Jacobs, Porter, Thomas) was material | The impeachment notes would have significantly undercut witness credibility and been used effectively at trial | The impeachment material was largely cumulative of impeachment actually presented at trial and thus would not have meaningfully altered jury confidence | Affirmed: cumulative impeachment insufficient to undermine confidence in verdict |
| Whether identity of alternative suspect (McMillan) and Luchie’s timing evidence could have supported an alternate-perpetrator defense | Those items, together with McMillan’s later similar offenses, could have allowed a unified defense pointing to another culprit and rebutting the group-attack narrative | Even with McMillan/Luchie, the record contained multiple independent accounts of a sizable group attack; defendants’ alternative theory would require discrediting multiple cooperating witnesses and eyewitnesses | Affirmed: alternative-perpetrator theory unlikely to persuade jury given the strong group-attack testimony |
Key Cases Cited
- Brady v. Maryland, 373 U.S. 83 (1963) (Brady rule: prosecution must disclose favorable material evidence that is material to guilt or punishment)
- United States v. Agurs, 427 U.S. 97 (1976) (withheld-evidence materiality assessed in context of the entire record)
- United States v. Bagley, 473 U.S. 667 (1985) (reasonable probability standard for withheld evidence and emphasis on confidence in outcome)
- Kyles v. Whitley, 514 U.S. 419 (1995) (suppressed evidence is material if it undermines confidence in outcome)
- Cone v. Bell, 556 U.S. 449 (2009) (reiterating reasonable probability test for Brady materiality)
- Smith v. Cain, 565 U.S. 73 (2012) (Brady materiality judged by whether suppressed evidence undermines confidence in verdict)
- Strickler v. Greene, 527 U.S. 263 (1999) (Brady framework: favorable, suppressed, material)
- Berger v. United States, 295 U.S. 78 (1935) (prosecutor’s duty: not simply to win but that justice shall be done)