Troy Mansfield v. Williamson County, Texas

Williamson County prosecutors knew Troy Mansfield was innocent of the heinous crime he was accused of—they had clear exculpatory evidence directly from the victim. Despite this Court’s holding in Brady v. Maryland that “suppression by the prosecution of evidence favorable to an accused upon request violates due process where the evidence is material either to guilt or to punishment,” they withheld it for months. 373 U.S. 83, 87 (1963). And then, just a few days before trial, prosecutors offered Mansfield what the court below called “a Hobson’s choice”: face 99 years to life in prison or serve less than 6 months for a crime he did not commit. Mansfield took the deal. When the truth emerged, a judge vacated Mansfield’s conviction on due process grounds. Mansfield sued under 42 U.S.C. § 1983, but the district court held that his Brady claim was foreclosed by circuit precedent declining to apply Brady to plea bargaining. The Fifth Circuit affirmed, further entrenching a well-defined split of authority among the circuits and state high courts. In separate concurrences, Judges Higginbotham and Costa recognized the “acknowledged circuit split,” argued that the Fifth Circuit was on the wrong side, and called on this Court to address the split, which—given the prevalence of pleas and the “untenable” disparity between the rights of defendants based purely on geographic happenstance—“begs for resolution.” The question presented is: Whether the due process right recognized in Brady requires the disclosure of exculpatory evidence (or at the very least, evidence of factual innocence) during pretrial plea negotiations.