Experimental. Doctrines is a new Annlex feature, starting with four areas: Self-incrimination, Brady, Terry and Miranda. Each page collects what courts have said about a leading case, quoted from the opinions that cite it. Annlex Chat uses these collections to help find relevant cases; what a case holds still comes from its opinion. We'd like to hear what's useful, missing or wrong: Send feedback
Reasonable-probability materiality (Brady materiality standard)
Leading case
United States v. Bagley, 473 U.S. 667 (1985)
How courts have described it
holding that there is no Brady violation unless a reasonable probability exists that the disclosed evidence would have altered the result of trial
United States v. Blackwell (6th Cir. 2006)
holding that in a Brady v. Maryland situation involving a failure to disclose exculpatory evidence, a defendant must show "a reasonable probability that, had the evidence been disclosed to the defense, the result of the proceeding would have been different”
Ferrara v. United States, 456 F.3d 278 (1st Cir. 2006)
holding that evidence is material under Brady if there is a reasonable probability that, had it been disclosed, the result of the proceeding would have been different
Miller v. Dretke, 431 F.3d 241 (5th Cir. 2005)
explaining that materiality exists when "there is a reasonable probability that, had the evidence been disclosed to the defense, the result of the proceeding would have been different”
Thomas Clyde Bowling, Jr. v. Phillip Parker, Warden, 344 F.3d 487 (6th Cir. 2003)
holding that exculpatory evidence is material “if there is a reasonable probability that, had the evidence been disclosed to the defense, the result of the proceeding would have been different”
Jernigan v. Richard, 907 F. Supp. 2d 998 (D. Ariz. 2012)
indicating that the materiality of exculpatory evidence is evaluated in reference to whether “the result of the proceeding would have been different.”
In Re: Ronald Seastrunk, 236 So. 3d 509 (La. 2017)
holding that “[tjhe evidence is material only if there is a reasonable probability that, had the evidence been disclosed to the defense, the result of the proceeding would have been different. A reasonable probability is a probability sufficient to undermine confidence in the outcome.”
Commonwealth v. Chambers, 807 A.2d 872 (Pa. 2002)
holding that [a] 'reasonable probability is a probability sufficient to undermine confidence in the outcome
People v. Mucklow, 35 P.3d 527 (Colo. 2000)
holding that “evidence is material only if there is a reasonable probability that, had the evidence been disclosed to the defense, the result of the proceeding would have been different”
State v. Howard, 433 S.E.2d 742 (N.C. 1993)
holding that undisclosed evidence in the Brady context “is material only if there is a reasonable probability that, had the evidence been disclosed to the defense, the result of the proceeding would have been different”
Gregory Marino v. State of Alaska (Alaska Ct. App. 2025)
holding that evidence is “material” only if there is a “reasonable probability” that it would alter the trial result
Christopher R. Stacy v. State of Alaska, 500 P.3d 1023 (Alaska Ct. App. 2021)
Related doctrines
- Cumulative Materiality of Suppressed Evidence (Brady)
- Duty to disclose material exculpatory evidence absent a specific request
About this page
The quotations above are from court opinions that cite the leading case, in each court's own words. The heading is a short label Annlex generated from those quotations. It has not been reviewed by a lawyer and is not legal advice.