In the case of Curtis Lee Kyles v. John P. Whitley, Warden (1994), the U.S Supreme Court ruled in favor of Kyles, a death row inmate who had been convicted for murder based on circumstantial evidence and eyewitness testimony. The court found that prosecutors had withheld significant exculpatory evidence during his trial which could have influenced the jury's decision-making process and potentially led to a different outcome. This withholding violated Kyles' constitutional rights under Brady v Maryland (1963) which requires disclosure of all favorable evidence to defendants by prosecution teams. The undisclosed material included various witness statements as well as physical items such as bullets from an unrelated crime scene that matched those used in the murder case against him, thereby casting doubt on his guilt.

In the dissenting opinion for Curtis Lee Kyles v. John P. Whitley, Warden, Justice Scalia disagreed with the majority's decision to overturn Kyles' conviction due to prosecutorial misconduct in withholding exculpatory evidence. He argued that even if all of the undisclosed evidence had been presented at trial, there was not a reasonable probability that it would have changed the outcome given other strong incriminating evidence against Kyles such as eyewitness testimony and physical evidence linking him to the crime scene and victim's car. Furthermore, he criticized the majority for overstepping its role by reevaluating witness credibility and making factual determinations which should be left up to juries rather than appellate courts. In his view, this case did not meet Brady violation standards because withheld information was either already known by defense or wasn't material enough to undermine confidence in verdict.