Case name: Napue v. Illinois

Opinion filed: 1959-06-15

Docket No.: 583

Citations:
• 3 L. Ed. 2d 1217
• 79 S. Ct. 1173
• 360 U.S. 264
• 1959 U.S. LEXIS 811

Case holding summaries:
• Fourteenth Amendment violation if “the State, although not soliciting false evidence, allows it to go uncorrected when it appears”
• the Supreme Court held that 4 the prosecution violated due process when it failed to correct testimony it knew to be false
• wherein a witness’s attempt to obtain a plea deal before testifying was material
• conviction reversed where a witness testified falsely that he received no consideration in return for his testimony and where such testimony “may have had an effect on the outcome of the trial”
• "The [fact-finders] estimate of the truthfulness and reliability of a given witness may well be determinative of guilt or innocence, and it is upon such subtle factors as the possible interest of the witness in testifying falsely that a defendant's life or liberty may depend."
• “[A]lthough not soliciting false evidence,” the government is bound to correct it “when it appears.”
• "The jury's estimate of the truthfulness and reliability of a given witness may well be determinative of guilt or innocence, and it is upon such subtle factors as the possible interest of the witness in testifying falsely that a defendant's life or liberty may depend"
• "The jury's estimate of the truthfulness and reliability of a given witness may well be determinative of guilt or innocence, and it is upon such subtle factors as the possible interest of the witness in testifying falsely that a defendant's life or liberty may depend."
• “The jury’s estimate of the truthfulness and reliability of a given witness may well be determinative of guilt or innocence . . . .”
• reversing when state used false testimony to secure conviction
• “The jury’s estimate of the truthfulness and reliability of a given witness may well be determinative of guilt or innocence, and it is upon such subtle factors as the possible interest of the witness in testifying falsely that a defendant’s life or liberty may depend.”
• allowing perjured testimony to stand
• Denial of due process exists even when uncorrected false testimony goes merely to witness credibility.
• prohibiting the state from knowingly relying upon false testimony or allowing false testimony to go uncorrected
• "The jury's estimate of the truthfulness and reliability of a given witness may well be determinative of guilt or innocence, and it is upon such subtle factors as the possible interest of the witness in testifying falsely that a defendant's life or liberty may depend"
• prosecutor's knowing failure to correct perjury
• “a conviction obtained through use of false evidence, known to be such by representatives of the State, must fall under the Fourteenth Amendment”
• knowing use of false testimony at trial
• reversing a conviction where the prosecution used false testimony that “may have had an effect on the outcome of the trial”
• knowing use of false testimony at trial
• “[I]t is established that a conviction obtained through use of false evidence, known to be such by representatives of the State, must fall under the Fourteenth Amendment.”
• “[I]t is established that a conviction obtained through use of false evidence, known to be such by representatives of the State, must fall under the Fourteenth Amendment.”
• use of false evidence at trial violated due process
• the witness "had falsely testified that he had been promised no consideration for his testimony"
• the witness "had falsely testified that he had been promised no consideration for his testimony," and "[h]ad the jury been apprised of the true facts, . . . it might well have concluded that [the witness] had fabricated testimony in order to curry the favor of [the prosecutor]"
• conviction must fall when the prosecution, "although not soliciting false evidence, allows it to go uncorrected when it appears"
• government "may not knowingly use false evidence, including false testimony"
• "The jury's estimate of the truthfulness and reliability of a given witness may well be determinative of guilt or innocence ...."
• principle that government may not knowingly use false evidence is 'implicit in any concept of ordered liberty'
• government must inform the defendant if it knows that one of its witnesses has perjured himself
• requiring a knowing use of perjured testimony to establish violation of due process
• recognizing "[t]he principle that a State may not knowingly use false evidence, including false testimony, to obtain a tainted conviction"
• "The jury’s estimate of the truthfulness and reliability of a given witness may well be determinative of guilt or innocence, and it is upon such subtle factors as the possible interest of the witness in testifying falsely that a defendant’s life or liberty may depend."
• Supreme Court is not bound by state or lower courts' determination that constitutional error did not affect verdict and must make independent examination of record
• government's failure to correct false testimony of a witness
• due process violated when government knowingly allows false testimony to go uncorrected
• refusing to dis- tinguish between exculpatory and impeachment evidence in cases involving prosecutorial misconduct
• conviction obtained through perjury, "known to be such by representatives of the State," violates due process, and the same result obtains when the State, although not soliciting perjury, allows it to go uncorrected when it appears
• Due process prohibits the State’s “knowin[g] use [of] false evidence,” because such use violates “any concept of ordered liberty.”
• “[A] conviction obtained * This disposition is not appropriate for publication and is not precedent except as provided by Ninth Circuit Rule 36-3. through use of false evidence, known to be such by representatives of the State, must fall under the Fourteenth Amendment.”
• failure to correct false evidence violates due process
• prosecution may not use false testimony
• noting that this principle is implicit in any concept of ordered liberty
• holding that the prosecution should have disclosed promise of some reduction in sentence for favorable testimony
• due process right to fair trial
• “[A] State may not knowingly use false evidence, including false testimony, to obtain a tainted conviction . . . .”
• "The jury's estimate of the truthfulness and reliability of a given witness may well be determinative of guilt or innocence, and it is upon such subtle factors as the possible interest of the witness in testifying falsely that a defendant's life or liberty may depend."
• even where the prosecution did not solicit false testimony, but allows it to go uncorrected when it appears, due process is violated
• noting that "[t]he jury's estimate of the truthfulness and reliability of a given witness may well be determinative of guilt or innocence, and it is upon such subtle factors as the possible interest of the witness in testifying falsely that a defendant's life or liberty may depend."
• "The principle that a State may not knowingly use false evidence, including false testimony, to obtain a tainted conviction, implicit in any concept of ordered liberty, does not cease to apply only because the false testimony goes only to the credibility of the witness."

plus-circle Add Review

comment

Reviews (1)