IN AGURS, THE COURT HELD THAT A CONVICTED CRIMINAL DEFENDANT WILL NOT BE GRANTED A NEW TRIAL ON THE GROUND THAT THE PROSECUTOR FAILED TO VOLUNTEER UNREQUESTED INFORMATION UNLESS THE UNDISCLOSED INFORMATION CREATES A REASONABLE DOUBT AS TO THE DEFENDANT'S GUILT. THIS NOTE ANALYZES THE FACTS OF THE CASE AND SURVEYS PREVIOUS FEDERAL CASE LAW DEALING WITH DUE PROCESS REQUIREMENTS FOR PROSECUTORIAL DISCLOSURE. THE STANDARD OF REVIEW ESTABLISHED BY THE AGURS COURT IS REVIEWED. THE AUTHOR CONCLUDES THAT THE AGURS DECISION REFLECTS THE COURT'S DESIRE TO SEE EXPANSION OF CRIMINAL DISCOVERY ACCOMPLISHED THROUGH PROCEDURAL REFORM AND NOT THROUGH CONSTITUTIONAL INTERPRETATION. (AUTHOR ABSTRACT MODIFIED)...EB