Bracy v. Gramley

520 U.S. 899 (1997)

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Nature of the Case

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Facts

Bracy (D) was tried, convicted, and sentenced to death before then-Judge Thomas J. Maloney for his role in an execution-style triple murder. Maloney was later convicted of taking bribes from defendants in criminal cases. The judge “fixed” other murder cases during and around the time of D's trial. D contends that Maloney, therefore, had an interest in a conviction to deflect suspicion that he was taking bribes in other cases and that this interest violated the fair-trial guarantee of the Fourteenth Amendment's Due Process Clause. Maloney was one of many dishonest judges exposed and convicted through “Operation Greylord,” a labyrinthine federal investigation of judicial corruption in Chicago. Maloney was convicted in Federal District Court of conspiracy, racketeering, extortion, and obstructing justice in April 1993. Four months later, D filed this habeas petition claiming, among other things, that he was denied a fair trial because “in order to cover up the fact that [Maloney] accepted bribes from defendants in some cases, [he] was prosecution oriented in other cases.” D sought discovery in support of this claim. Specifically, he requested (1) the sealed transcript of Maloney's trial; (2) reasonable access to the prosecution's materials in Maloney's case; (3) the opportunity to depose persons associated with Maloney; and (4) a chance to search Maloney's rulings for a pattern of pro-prosecution bias. The Court rejected D's fair-trial claim and denied his supplemental motion for discovery. The Court of Appeals affirmed by a divided vote. The court concluded that because D had failed to uncover any evidence of actual bias without discovery, “the probability is slight that a program of depositions aimed at crooks and their accomplices . . . will yield such evidence.” The Supreme Court granted certiorari.