Featured Chrome Extensions:

Casey IRACs are produced by an AI that analyzes the opinion’s content to construct its analysis. While we strive for accuracy, the output may not be flawless. For a complete and precise understanding, please refer to the linked opinions above.

Keywords

defendantattorneyappealtrialpleadue processbad faithmaterialityexculpatory evidence
appealpleadue processbad faithmaterialityexculpatory evidence

Related Cases

Wilson P. Abraham Const. Corp. v. Armco Steel Corp., 559 F.2d 250, 1977-2 Trade Cases P 61,625
View Case »
DCH Health Services Corp. v. Waite, 95 Cal.App.4th 829, 115 Cal.Rptr.2d 847, 02 Cal. Daily Op. Serv. 869, 2002 Daily Journal D.A.R. 1063
View Case »
People v. Nash, 418 Mich. 196, 341 N.W.2d 439
View Case »
Diversified Industries, Inc. v. Meredith, 572 F.2d 596, 23 Fed.R.Serv.2d 1473, 24 Fed.R.Serv.2d 1201, 1977-2 Trade Cases P 61,591, 1978-1 Trade Cases P 61,879
View Case »
U.S. v. Goldberger & Dubin, P.C., 935 F.2d 501, 67 A.F.T.R.2d 91-1166, 60 USLW 2001, 91-2 USTC P 50,315, 33 Fed. R. Evid. Serv. 14
View Case »
Justia Law Link
LexisNexis Link
Westlaw Link
CourtListener Link
Oyez Link

Miller v. Angliker, 848 F.2d 1312

Facts

Benjamin F. Miller, Jr. was committed to a mental health facility after being found not guilty of several murders by reason of insanity. He contended that his confinement was due to violations of his Sixth Amendment right to effective counsel and his due process right to exculpatory information withheld by the State. The State had evidence linking another individual, Robert Lupinacci, to the murders, which was not disclosed to Miller or his attorney prior to his plea agreement. The district court denied Miller's habeas petition, leading to his appeal.

Benjamin F. Miller, Jr. was committed to a mental health facility after being found not guilty of several murders by reason of insanity.

Issue

Whether the district court properly evaluated the materiality of the withheld evidence in light of Miller's claim under Brady v. Maryland and his assertion of ineffective assistance of counsel.

Whether the district court properly evaluated the materiality of the withheld evidence in light of Miller's claim under Brady v. Maryland and his assertion of ineffective assistance of counsel.

Rule

The suppression of evidence favorable to the accused violates due process if the evidence is material to guilt or punishment, irrespective of the prosecution's good or bad faith.

The suppression of evidence favorable to the accused violates due process if the evidence is material to guilt or punishment, irrespective of the prosecution's good or bad faith.

Analysis

The court determined that the withheld evidence regarding Robert Lupinacci was material because it could have influenced Miller's decision to plead insanity rather than not guilty. The court noted that the standards for evaluating Brady claims should apply equally to defendants who plead not guilty by reason of insanity, as such pleas waive important trial rights. The court found that the state courts had applied an incorrect standard in assessing the materiality of the evidence.

The court determined that the withheld evidence regarding Robert Lupinacci was material because it could have influenced Miller's decision to plead insanity rather than not guilty.

Conclusion

The court reversed the district court's denial of Miller's habeas petition, concluding that the withheld evidence was material and that Miller was entitled to relief unless the State opted to retry him.

The court reversed the district court's denial of Miller's habeas petition, concluding that the withheld evidence was material and that Miller was entitled to relief unless the State opted to retry him.

Who won?

Benjamin F. Miller, Jr. prevailed in the appeal because the court found that the State's failure to disclose exculpatory evidence violated his due process rights.

Benjamin F. Miller, Jr. prevailed in the appeal because the court found that the State's failure to disclose exculpatory evidence violated his due process rights.

You must be