United States v. Agurs is a landmark 1976 decision of the Supreme Court of the United States that clarified the constitutional duty of prosecutors to disclose exculpatory evidence to criminal defendants. The case examined whether the prosecution’s failure to disclose a victim’s criminal record violated the defendant’s right to a fair trial under the Due Process Clause.
In United States v. Agurs, the Court refined the concept of “materiality” and explained when nondisclosure of evidence amounts to a constitutional violation. This decision plays an important role in understanding the limits of the disclosure obligation established earlier under Brady v. Maryland.
Brief Fact Summary of United States v. Agurs
In United States v. Agurs, the defendant was convicted of second-degree murder after a fatal stabbing during a struggle in a motel room. After the trial, defense counsel discovered that the victim had an extensive criminal record. The defense argued that this information should have been disclosed by the prosecution because it could have supported the defendant’s claim of self-defense. A motion for a new trial was filed on the ground that the prosecution’s failure to disclose this information violated due process.
Facts of United States v. Agurs Case
The defendant, Linda Agurs, was convicted of second-degree murder for the stabbing death of James Sewell, the victim. On September 24, 1971, the defendant and the victim checked into a hotel, registering as husband and wife. At the time, the victim was carrying two knives—one was a bowie knife, and the other was a pocketknife. The victim’s estranged wife later testified that he had been carrying $360 earlier that same day.
Approximately fifteen minutes after checking into the room, three hotel employees heard the defendant screaming for help. The employees forced their way into the room and found the defendant and the victim struggling over possession of one of the knives. The victim had sustained multiple stab wounds. The employees separated the parties and contacted the police.
The victim was taken to the hospital and was declared dead on arrival. The defendant did not have any knife wounds. No money was found among the victim’s personal belongings. After leaving the motel, the defendant turned herself in to the police the following day.
At trial, the defendant did not present evidence and relied on a claim of self-defense. The jury deliberated briefly and found the defendant guilty of second-degree murder.
Procedural History
Three months after the conviction, defense counsel filed a motion for a new trial. The motion alleged three main points:
- The victim had a prior criminal record indicating a history of violence.
- The prosecution had failed to disclose this criminal record to the defense.
- Recent precedent from the United States Court of Appeals for the District of Columbia Circuit made such evidence admissible even if the defendant was unaware of the victim’s past.
The United States District Court for the District of Columbia denied the motion for a new trial. On appeal, the United States Court of Appeals for the District of Columbia Circuit reversed the decision, holding that the undisclosed evidence was material.
The case was then reviewed by the Supreme Court, leading to the decision in United States v. Agurs.
Issue
The primary issue in United States v. Agurs was whether the prosecutor has a constitutional duty to voluntarily disclose exculpatory evidence to the defense when no specific request for that evidence has been made, and if so, what standard of materiality governs that duty.
United States v. Agurs Judgment
The Supreme Court in United States v. Agurs held that the prosecution’s failure to disclose the victim’s criminal record did not deprive the defendant of a fair trial. The Court concluded that no constitutional error occurred because the undisclosed evidence did not meet the standard of materiality required under due process.
Court’s Reasoning in United States v. Agurs
Justice John Paul Stevens wrote the majority opinion. The Court distinguished United States v. Agurs from earlier cases applying the Brady rule. The Court identified three situations addressed under Brady:
First, cases where the prosecution knowingly uses perjured testimony or fails to correct testimony it knows or should know is false.
Second, cases where the defense makes a specific pretrial request for particular evidence.
Third, cases where the defense makes a general request for exculpatory evidence or makes no request at all.
The Court explained that when a general request is made, it places the prosecutor in nearly the same position as when no request is made. In both situations, the prosecutor has a duty to disclose truly exculpatory evidence, but the constitutional standard is not automatic disclosure of everything that might be helpful to the defense.
In United States v. Agurs, the defense did not request the victim’s criminal record, and the undisclosed record did not involve perjury. The Court emphasized that the Constitution does not require the prosecution to disclose all information that could potentially influence a jury. Instead, the focus is on whether the omission undermines confidence in the outcome of the trial.
The Court further clarified that the prosecutor’s intent or moral culpability is not the measure of a constitutional violation. The key inquiry is the nature of the evidence itself. If the suppressed evidence is so significant that it creates a reasonable doubt that did not otherwise exist, then a constitutional violation has occurred.
Applying this standard, the Court concluded that the victim’s criminal record did not create such a reasonable doubt. The trial judge, after reviewing the entire record, remained convinced of the defendant’s guilt beyond a reasonable doubt.
Dissenting Opinion
Justice Thurgood Marshall dissented. He argued that the majority’s interpretation of materiality was too narrow and placed criminal defendants at a disadvantage. According to the dissent, limiting disclosure obligations in this manner weakened the protections established under Brady and reduced the fairness of criminal trials.
Conclusion
In United States v. Agurs, the Supreme Court held that the Constitution does not require prosecutors to disclose all potentially helpful evidence to the defense. Instead, nondisclosure violates due process only when the omitted evidence is material in the constitutional sense—meaning it creates a reasonable doubt of guilt that did not otherwise exist. The case remains a key authority in understanding prosecutorial disclosure duties and the concept of materiality in criminal law.