United States v. Williams (1992)

United States v. Williams, (90-1972), 504 U.S. 36 (1992), was a decision by the Supreme Court of the United States, concerning the presentation of exculpatory evidence to a grand jury, ruling that the federal courts do not have the supervisory power to require prosecutors to present exculpatory evidence to the grand jury. The opinion was written by Justice Scalia, and the dissent by Justice Stevens. ^[1]

The question addressed by the court, was if there were grounds for prosecutorial misconduct – which would require the dismissal of an indictment – for the prosecutor to withhold “substantial exculpatory evidence” that could lead the grand jury to reject the indictment.^[2] The significance of the ruling lies not only in its definition of the duty of the prosecutor in regard to presenting exculpatory evidence before the grand jury, but also in its definition of the grand jury's accusatory role.^[1]

The ruling protects prosecutors who withhold "substantial exculpatory evidence" in order to obtain an indictment, as the role of the grand jury is not to determine guilt, but rather to decide whether there is enough evidence of a crime; exculpatory evidence can be presented at trial. The dissent from Stevens focused on the argument that a prosecutor's failure to present substantially exculpatory evidence is a form of prosecutorial misconduct, but that nevertheless, the prosecutor need not "ferret out and present all evidence that could be used at trial to create a reasonable doubt as to defendant's guilt."^[2]

References

1. "United States v. Williams (90-1972), 504 U.S. 36 (1992).". Legal Information Institute. Archived from the original on 18 December 2014. Retrieved 18 December 2014.
2. Citron, Eric (November 25, 2014). "Cases and controversies: Not your typical grand jury investigation". SCOTUSblog. Archived from the original on December 13, 2014. Retrieved December 12, 2014.