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Keywords

defendanttrialtestimonyhung jurywitness testimonymaterialityexculpatory evidencecredibility
defendanttrialtestimonyhung jurywitness testimonymateriality

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Kyles v. Whitley, 514 U.S. 419, 115 S.Ct. 1555, 131 L.Ed.2d 490, 63 USLW 4303

Facts

Curtis Lee Kyles was convicted of first-degree murder and sentenced to death after a second trial, following a hung jury in his first trial. The prosecution's case relied heavily on eyewitness testimony, but it was later revealed that the State had failed to disclose several pieces of evidence favorable to Kyles, including eyewitness statements and information from an informant. Kyles claimed that the prosecution's suppression of this evidence violated his rights under Brady v. Maryland, which requires the disclosure of exculpatory evidence.

Curtis Lee Kyles was convicted of first-degree murder and sentenced to death after a second trial, following a hung jury in his first trial. The prosecution's case relied heavily on eyewitness testimony, but it was later revealed that the State had failed to disclose several pieces of evidence favorable to Kyles, including eyewitness statements and information from an informant.

Issue

Did the prosecution's failure to disclose evidence favorable to the defendant constitute a violation of Brady v. Maryland, and did the cumulative effect of the suppressed evidence undermine confidence in the outcome of the trial?

Did the prosecution's failure to disclose evidence favorable to the defendant constitute a violation of Brady v. Maryland, and did the cumulative effect of the suppressed evidence undermine confidence in the outcome of the trial?

Rule

The prosecution has an obligation under Brady v. Maryland to disclose evidence favorable to the defense, and the materiality of such evidence is determined by considering its cumulative effect rather than item by item.

The prosecution has an obligation under Brady v. Maryland to disclose evidence favorable to the defense, and the materiality of such evidence is determined by considering its cumulative effect rather than item by item.

Analysis

The Court analyzed the suppressed evidence, concluding that its cumulative effect raised a reasonable probability that its disclosure would have led to a different result at trial. The Court emphasized that the prosecution's case was significantly weakened by the undisclosed eyewitness statements and the inconsistencies in the informant's testimony, which could have been used to challenge the credibility of the State's case.

The Court analyzed the suppressed evidence, concluding that its cumulative effect raised a reasonable probability that its disclosure would have led to a different result at trial.

Conclusion

The Supreme Court reversed the decision of the lower courts and remanded the case for a new trial, finding that the nondisclosure of evidence constituted a Brady violation.

The Supreme Court reversed the decision of the lower courts and remanded the case for a new trial, finding that the nondisclosure of evidence constituted a Brady violation.

Who won?

Curtis Lee Kyles prevailed in the case because the Supreme Court found that the prosecution's failure to disclose favorable evidence violated his rights and undermined the fairness of his trial.

Curtis Lee Kyles prevailed in the case because the Supreme Court found that the prosecution's failure to disclose favorable evidence violated his rights and undermined the fairness of his trial.

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