Bracy v. Gramley
United States Supreme Court
520 U.S. 899 (1997)
Bracy (defendant) was convicted and sentenced to death by Judge Maloney, who was later convicted of accepting bribes and other corruption tied to organized crime. Bracy theorized that Maloney, to cover up his bribe-taking in other cases, deliberately favored the prosecution in cases like his own where no bribe was paid — and pointed out that his own defense attorney was a former associate of Maloney's, from a law firm otherwise linked to corruption, possibly appointed to rush his trial. The district court denied both his fair-trial claim and his request for discovery to investigate it, finding the allegations too speculative and lacking good cause under habeas discovery rules; the court of appeals affirmed in a divided vote, and the Supreme Court granted certiorari.
Whether a habeas petitioner convicted by a judge who was himself later convicted of corruption can establish good cause to obtain discovery in support of a judicial-bias claim.