In Alcorta, the Supreme Court held that the Fourteenth Amendment due process clause bars prosecutors from knowingly presenting perjured testimony in a criminal case.
Alcorta stabbed his wife to death after finding her in a parked car with another man, Castilleja. Charged with murder, Alcorta claimed that he should be convicted of a lesser offense because he acted in the heat of passion after seeing his wife kissing Castilleja. At Alcorta’s trial, Castilleja testified that his relationship with Alcorta’s wife was nothing more than a casual friendship, and Alcorta was convicted of murder. After the conviction, however, Castilleja admitted that he had been engaged in a sexual relationship with Alcorta’s wife and that the prosecutor had told him not to volunteer any information about that sexual relationship.
After the state courts refused to order a new trial, Alcorta appealed to the U.S. Supreme Court, which unanimously reversed. The Court observed that Castilleja’s testimony gave the false impression that his relationship with Alcorta’s wife was mere friendship and thereby refuted Alcorta’s claim that he acted passionately after seeing his wife kissing Castilleja. Since the prosecutor knew Castilleja’s testimony was false, the Court concluded that Alcorta had been denied due process. The Court’s emphasis on the prosecutor’s duty to avoid presenting perjured testimony, later clarified and expanded in Napue v. Illinois, 360 U.S. 264 (1959), laid the groundwork for later cases, such as Brady v. Maryland, 373 U.S. 83 (1963), and Kyles v. Whitley, 514 U.S. 419 (1995), which required the prosecution to disclose evidence favorable to the defendant.
DAVID A. MORAN
References and Further Reading
Cases and Statutes Cited
See also Brady v. Maryland, 373 U.S. 83 (1963); Due Process; Fourteenth Amendment; Kyles v. Whitley, 514 U.S. 419 (1995); Napue v. Illinois, 360 U.S. 264 (1959)