Breyer, joined by Kennedy, Thomas, Ginsburg, Alito, Sotomayor, Kagan, Gorsuch
Turner v. United States was a United States Supreme Court case that examined whether the convictions in the 1984 case involving the violent sexual assault and murder of Catherine Fuller in Washington, D.C. was misled by the prosecution because of failure to disclose evidence which was in violation of the defendant's constitutional rights under Brady v. Maryland.[1] The court was questioned whether the undisclosed evidence requires the defendant's convictions to be overturned.[2]
Catherine Fuller was a 49-year old mother of six living in Washington, D.C. On October 1, 1984, she suffered several internal injuries resulting from a brutal "gang assault." The conviction was largely based on eyewitness testimony and confessions some of which were later retracted or called into question. Eight individuals were convicted including Christopher Turner.
Almost two decades after the trial, the defense uncovered evidence that had not been disclosed by the prosecution at the time of the trial.[3] The evidence suggested Fuller may have been attacked by one or individuals rather than by a large group of men. They suggested a man named James McMillan may have been responsible as he had committed a similar assault in the same neighborhood on the same day Fuller was murdered.[4] Further evidence raised serious questions about the credibility of the prosecution's key witness in regards to their potential motives.
Argument
The main legal issue in Turner v. United States was whether the government's failure to disclose all evidence violated the defendants' rights under Brady v. Maryland 373, U.S. 83 (1963). The court was asked if the evidence was disclosed during trial if there was a reasonable probability that the outcome of the trial would have been different.[5] The undisclosed evidence suggested that it was in fact not a "gang assault" and was in fact McMillan that was involved in Fuller's murder. Additionally, it challenged the prosecutors timeline and brought questions to the government's key witness and argued if the evidence was shown it would have led at least one juror to reach a different decision therefore a different result.
Additionally, the case brought broader concerns within the legal community, including ethical obligations of prosecutors and the challenges that come with potential wrongful convictions. Critics argued that withheld evidence suppressed materials and the potential effect on the jury's deliberations.
Supreme Court decision
Justice Breyer
After further evaluation in regards to the arguments, the Supreme Court concluded that the withheld evidence was not relevant enough to have made a difference. In a 6-2 decision, the court upheld the convictions.[6] They argued that the withheld evidence, though it lacked physical evidence, was material to their defense and was not material under Brady v. Maryland because there was no "reasonable probability" that the verdict would've been any different.[7]
The dissenting justice disagreed and argued that if the evidence was shown, it would have allowed the defense to present an alternative narrative that could have persuaded at least one of the jurors. Regardless, the majority concluded that the withheld evidence was not material under Brady which reaffirmed the defendants' convictions.
Significance
Supreme Court Building
The Supreme Court's decision in this case clarified how the rules from Brady v. Maryland applies when the prosecution fails to share important evidence with the defense. In this ruling, the court stated that in order for the conviction to be overturned on these grounds, the withheld evidence must be strong enough to withhold a chance in the trial and create reasonable probability that the outcome of the trail will be different. By setting this high standard, the court raised the bar for defendants who are seeking new trails. This decision significantly influenced how courts start evaluating allegations of unfair trails, which makes it more difficult for defenders to challenge older convictions even when new and more compelling information comes to light. As a result, the ruling has had lasting implications under Brady.[1]
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