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Criminal Procedure Keyed to Dressler
United States v. Williams
Citation:
504 U.S. 36, 112 S.Ct. 1735, 118 L.Ed.2d 352.Facts
The defendant was indicted by a grand jury for bank fraud. He filed a motion for disclosure of all exculpatory portions of the grand jury transcripts. After reviewing the evidence, the defendant demanded that the District Court dismiss the indictment, alleging that the Government had failed to fulfill its obligation to present substantial exculpatory evidence to the grand jury.
The District Court dismissed the indictment, finding that the withheld evidence was relevant to an essential element of the crime charged. The United States Court of Appeals for the Tenth Circuit affirmed, finding that the Government’s behavior substantially influenced the grand jury’s decision to indict.
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