Evidence withheld by the Government was not material under Brady. In 1985, a group of defendants were tried together in the Superior Court for the District of Columbia for the kidnaping, armed robbery, and murder of Catherine Fuller. Long after their convictions became final, it emerged that the Government possessed certain evidence that it failed to disclose to the defense. The only question before the Court was whether the withheld evidence was “material” under Brady. The Court held it was not, finding that the withheld evidence as “too little, too weak, or too distant from the main evidentiary points to meet Brady’s standards.” [Author’s note: For a more detailed discussion of the withheld evidence and the Court’s reasoning, see my colleague’s blog post here].