Whether the Third Circuit's Brady materiality test—under which suppressed evidence is immaterial if it contradicts the prosecution's trial evidence—conflicts with this Court's decision in Kyles?

QUESTION PRESENTED In Brady v. Maryland, 373 U.S. 83 (1963), this Court held that the prosecution violates due process when it withholds favorable evidence and the evidence is material to the defendant’s conviction or sentence. In Kyles v. Whitley, this Court elaborated on the materiality standard, explaining that materiality is demonstrated when “there is a reasonable probability that, had the evidence been disclosed to the defense, the result of the proceeding would have been different.” 514 U.S. 419, 483— 34 (1995). This standard, the Court explained, “is not a sufficiency of the evidence test. A defendant need not demonstrate that after discounting the inculpatory evidence in light of the undisclosed evidence there would not have been enough left to convict.” Id. at 434-35. Rather, the question is “whether we can be confident that the jury’s verdict would have been the same.” Id. at 453. In this case, the Commonwealth suppressed evidence undermining its linchpin witness’s testimony. But in reviewing Petitioner Sheldon Hannibal’s Brady claim, the Third Circuit inverted the Kyles materiality standard, holding that the suppressed evidence was immaterial because it contradicted other evidence presented by the Commonwealth at trial. The question presented is: Whether the Third Circuit’s Brady materiality test—under which suppressed evidence is immaterial if it contradicts the prosecution’s trial evidence—conflicts with this Court’s decision in Kyles? i