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Keywords

defendanttrialtestimonydue processmateriality
defendanttrialtestimonydue processmateriality

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Smith v. Cain, 565 U.S. 73, 132 S.Ct. 627, 181 L.Ed.2d 571, 80 USLW 4028, 12 Cal. Daily Op. Serv. 432, 2012 Daily Journal D.A.R. 296, 23 Fla. L. Weekly Fed. S 32

Facts

On March 1, 1995, Larry Boatner and several friends were at a home in New Orleans when armed men entered, demanding money and drugs, resulting in the deaths of five people. Boatner identified Smith as one of the gunmen during the trial, but later, Smith obtained police notes revealing that Boatner had previously stated he could not identify any of the perpetrators. The trial relied solely on Boatner's testimony, with no other witnesses or physical evidence linking Smith to the crime.

On March 1, 1995, Larry Boatner and several friends were at a home in New Orleans when armed men entered, demanding money and drugs, resulting in the deaths of five people. Boatner identified Smith as one of the gunmen during the trial, but later, Smith obtained police notes revealing that Boatner had previously stated he could not identify any of the perpetrators. The trial relied solely on Boatner's testimony, with no other witnesses or physical evidence linking Smith to the crime.

Issue

Did the prosecution's failure to disclose the eyewitness's contradictory statements violate Smith's rights under Brady v. Maryland?

Did the prosecution's failure to disclose the eyewitness's contradictory statements violate Smith's rights under Brady v. Maryland?

Rule

Under Brady v. Maryland, the State violates a defendant's right to due process if it withholds evidence that is favorable to the defense and material to the defendant's guilt or punishment.

Under Brady v. Maryland, the State violates a defendant's right to due process if it withholds evidence that is favorable to the defense and material to the defendant's guilt or punishment.

Analysis

The Court found that the undisclosed statements from Boatner were material because they directly contradicted his trial testimony, which was the only evidence linking Smith to the crime. The Court emphasized that the likelihood of a different result was significant enough to undermine confidence in the trial's outcome, thus satisfying the materiality requirement under Brady.

The Court found that the undisclosed statements from Boatner were material because they directly contradicted his trial testimony, which was the only evidence linking Smith to the crime. The Court emphasized that the likelihood of a different result was significant enough to undermine confidence in the trial's outcome, thus satisfying the materiality requirement under Brady.

Conclusion

The Supreme Court reversed the judgment of the Louisiana courts and remanded the case for further proceedings, granting Smith a new trial due to the Brady violation.

The Supreme Court reversed the judgment of the Louisiana courts and remanded the case for further proceedings, granting Smith a new trial due to the Brady violation.

Who won?

Juan Smith prevailed in the case because the Supreme Court determined that the prosecution's failure to disclose material evidence violated his due process rights.

Juan Smith prevailed in the case because the Supreme Court determined that the prosecution's failure to disclose material evidence violated his due process rights.

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