Whether a defendant must show inability to obtain suppressed, exculpatory evidence through independent efforts to establish a Brady violation

QUESTION PRESENTED Whether, to establish a violation of Brady v. Maryland, 373 U.S. 83 (1963), a defendant must show that he could not have obtained the suppressed, exculpatory evidence through his own independent efforts of “self-help” or “due diligence” as the Fourth Circuit and five other circuits have held, or whether the defendant’s failure to uncover the evidence independently is irrelevant, as the remaining six courts of appeals have held.