Kyles v. Whitley

Kyles v. Whitley, 514 U.S. 419 (1995) is a United States Supreme Court case that held that a prosecutor has an affirmative duty to disclose evidence favorable to a defendant.

Kyles was convicted of murder. Beanie was the main person who originally inculpated Kyles even though later there were many eye witnesses who identified Kyles as the murderer. The police/state never disclosed to the defense inconsistent statements made by Beanie, statements made by Beanie where he incriminated himself, inconsistent descriptions made by the eye witnesses, and several other pieces of potentially exculpatory evidence. The court held that Kyles should be granted a new trial. The court noted that Brady held that the suppression by the prosecution of evidence favorable to an accused upon request violates due process where the evidence is material either to guilt or to punishment, irrespective of the good faith or bad faith of the prosecution. It also discussed Bagley and the reasonable probability of a different result standard. “The question is not whether the defendant would more likely than not have received a different verdict with the evidence, but whether in its absence he received a fair trial, understood as a trial resulting in a verdict worthy of confidence.” It noted that this test was not a sufficiency of the evidence test. “A defendant need not demonstrate that after discounting the inculpatory evidence in light of the undisclosed evidence, there would not have been enough left to convict. Finally, they noted that the evidence must be considered on a whole, not piece by piece. Ultimately they found that based on the evidence that was not brought to light, a reasonable juror could have found Kyles not guilty. [Kyles v. Whitley]