In the case of Strickler v. Greene, the United States Supreme Court considered whether the Commonwealth of Virginia had violated Brady v. Maryland (Brady violations). In 1990, Thomas David Strickler and Ronald Henderson abducted, robbed, and murdered Leanne Whitlock. Strickler was convicted of capital murder and sentenced to death. Because of the prosecution’s open file policy, Strickler’s counsel did not file a pre-trial motion for discovery of possible exculpatory evidence. Strickler filed several appeals on the basis that his counsel provided ineffective assistance in failing to file a motion under Brady v. Maryland where the prosecution is obligated to disclose exculpatory evidence. The Supreme Court granted a certiorari to see whether the Commonweath had violated the 1963 Brady rule, and if so, whether Strickler had established the prejudice necessary to undermine confidence in the jury’s verdict, thereby creating the reasonable probability standard where the result of the trial would have been different had the suppressed documents been disclosed to the defense. In Strickler v. Greene, the Supreme Court preserved reasonable probability as the standard by which to measure whether the defendant received a fair trial in the absence of certain exculpatory material undisclosed to the defense. By preserving the reasonable probability standard in resolving issues of prejudice in Brady violations, the majority rejected the “sliding scale significant” possibility standard, due to its inability to establish materiality in the constitutional sense and that reasonable probability was more appropriate to ensure that due process rights were protected and injustice prevented.