holding that evidence may be material for Brady purposes "where the Commonwealth's failure to disclose such evidence adversely affected the presentation of the defense at trial, or the defense's preparation for trial, such that there is a reasonable probability that, had the evidence been disclosed to the defense, the result of the proceeding would have been different"
How later courts described this case
- holding that evidence may be material for Brady purposes "where the Commonwealth's failure to disclose such evidence adversely affected the presentation of the defense at trial, or the defense's preparation for trial, such that there is a reasonable probability that, had the evidence been disclosed to the defense, the result of the proceeding would have been different"
- stating that “a defendant necessarily must identify specific evidence or information that would have been uncovered, and explain how that evidence or information would have changed the result of the proceeding,” and that mere speculation by a defendant is insufficient
- explaining that whether the “Commonwealth’s failure to disclose…[inadmissible] evidence adversely affected the presentation of the defense at trial, or the defense’s preparation for trial” cannot be based upon “mere speculation”
- noting that admissibility at trial is not a prerequisite to. disclosure under Brady j. If the Commonwealth has violated its discovery obligations, the trial court is authorized to impose sanctions: (E
Written by the judges who cited it.
The opinion
Justice SAYLOR,
concurring.
I join the Opinion Announcing the Judgment of the Court, except for the treat *685 ment of Commonwealth v. Green, 536 Pa. 599 , 640 A.2d 1242 (1994). I find the reasoning of Green too cryptic to provide a useful platform for clarification.