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Keywords

discoveryappealtrialtestimonywilldue processcredibility
defendantappealtrialtestimonydue process

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Gollehon v. State, 296 Mont. 6, 986 P.2d 395, 1999 MT 210

Facts

William Gollehon was convicted of deliberate homicide and sentenced to death for the murder of fellow inmate Gerald Pileggi, who was beaten to death during a prison softball game. After his conviction was affirmed, Gollehon filed a petition for postconviction relief, claiming that the prosecution failed to disclose agreements with key witnesses that could have affected their credibility. The court allowed discovery of postconviction agreements but ultimately found no evidence of undisclosed pretrial agreements or false testimony.

The Petitioner was convicted in the District Court of Powell County of deliberate homicide by accountability and sentenced to death on March 19, 1992.

Issue

Did the prosecution violate Gollehon's due process rights by failing to disclose agreements with witnesses, and was the court improperly constituted during the direct appeal?

The Supreme Court held that: (1) petitioner failed to show Brady violation regarding pretrial agreements with witnesses; (2) absent pretrial agreement, posttrial benefits conferred upon witnesses could not constitute Brady violation; (3) petitioner failed to prove existence of false testimony by prosecution witnesses that otherwise violated his due process rights, and (4) claim that Supreme Court was improperly constituted when it heard direct appeal was procedurally barred.

Rule

The prosecution has a duty to disclose evidence favorable to the accused, including agreements with witnesses that could affect their credibility, as established in Brady v. Maryland. A Brady violation requires proof of an undisclosed agreement or understanding that provided tangible benefits to a witness.

The suppression by the prosecution of material evidence favorable to the accused violates the defendant's Fourteenth Amendment guarantee of due process.

Analysis

The court analyzed whether Gollehon could establish a Brady violation by demonstrating that the prosecution suppressed evidence of agreements with witnesses Armstrong and Arnot. It concluded that Gollehon failed to provide evidence of any pretrial agreements and that the posttrial benefits conferred upon the witnesses did not constitute a Brady violation since there was no agreement prior to trial.

In summary, we conclude that the Petitioner has not established the existence of any undisclosed pretrial agreement between the State and Armstrong in exchange for his testimony.

Conclusion

The Supreme Court denied Gollehon's Amended Petition for Postconviction Relief, concluding that he did not establish any Brady violations or false testimony by witnesses.

Therefore, IT IS HEREBY ORDERED that the Amended Petition for Postconviction Relief is denied.

Who won?

The State prevailed in the case because Gollehon failed to prove any violations of his constitutional rights regarding witness agreements or the composition of the court during his direct appeal.

Petition denied.

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