How extensive is the Brady obligation

Ask the prosecutor in this case.

In re Kline.

Military prosecutors are bound by Service rules of professional responsibility.  Those rules are based on the ABA Model Rules.

The ethical rule regarding prosecutorial disclosure in the District of Columbia, as in most states, incorporated the “tends to negate guilt” standard promulgated by the ABA in its Model Code of Professional Responsibility to define the class of evidence required to be disclosed under Rule 3.8.

The Supreme Court reiterated that basic tenet in Cone, noting that “[a]lthough the Due Process Clause of the Fourteenth Amendment, as interpreted by Brady, only mandates the disclosure of material evidence, the obligation to disclose evidence favorable to the defense may arise more broadly under a prosecutor’s ethical or statutory obligations.” Cone v. Bell, 556 U.S. 449, 470 n.15 (2009) (citations omitted).