In the 1991 case United States v. John H. Williams, Jr., the Supreme Court of the United States addressed whether a prosecutor's failure to disclose evidence favorable to an accused violates due process where the defendant had not requested such information. The court held that regardless of request, suppression by prosecution of evidence favorable to an accused upon request violates due process where it is material either to guilt or punishment, irrespective of good faith or bad faith on part of prosecution. In this particular case, Williams was convicted for misapplication and theft from a federally insured savings and loan association but later discovered that some exculpatory documents were withheld during his trial which could have potentially influenced its outcome in his favor.

In the dissenting opinion for United States v. John H. Williams, Jr., it was argued that the majority's decision to uphold Williams' conviction under 18 U.S.C § 1001, which makes it a crime to lie to federal officials, was overly broad and could potentially criminalize innocent conduct. The dissent contended that this statute should only apply when false statements are made in contexts where they have the potential to pervert governmental functions or mislead government agencies into taking action they would not otherwise take. In this case, Williams had lied about his identity during an unrelated investigation; however, these lies did not interfere with any ongoing investigations nor were they intended to deceive investigators into altering their course of action. Therefore, according to the dissenting justices, applying § 1001 in such circumstances stretched its interpretation beyond what Congress originally intended and risked infringing upon individuals' rights against self-incrimination.