In Mooney v. Holohan, the Supreme Court set forth the principle that deliberate suppression by the prosecution of material evidence favorable to the accused constitutes a denial of due process. The Court has also ruled that the prosecution cannot withhold evidence at trial specifically requested by the defendant. An examination of the Court's rationale for allowing discovery suggests that it should be equally applicable to the preplea situation, redressing the imbalance of resources between the prosecution and the defense and maximizing the efficient use of prosecutorial and judicial services. The Court has interpreted the due process clause to mandate that a criminal prosecutor reveal material evidence favorable to the accused, but has used a sliding standard of materiality depends on the degree of prosecutorial misconduct and the defendant's initiative in requesting information. The Court has failed to make clear when a prosecutor must reveal material evidence to the accused, and it has been argued that discovery is unnecessary prior to the plea bargaining. Several factors support preplea discovery, such as fairness to the defendant in predicting the likely outcome of a trial and allowing legal counsel to evaluate the case effectively. Preplea exchanges of information help to ensure the plea's constitutionality by upholding the standard of voluntariness. Moreover, due process should require that evidence material to the question of guilt or punishment and affecting the credibility of key witnesses be disclosed prior to plea. The article contains 79 footnotes.