January 10, 2012

Supreme Court Decides Smith v. Cain

On January 10, 2012, the Supreme Court decided Smith v. Cain, No. 10-8145, holding that the State of Louisiana's failure to produce evidence impeaching eyewitness testimony violated the disclosure rule of Brady v. Maryland, 373 U.S. 83 (1963), requiring a new trial on a first-degree murder conviction.

Petitioner Juan Smith was convicted in the State of Louisiana for first degree murder.  At Smith's trial, a single witness, Larry Boatner, linked Smith to the crime.  Boatner testified that, while he was at a friend's house, two gunmen entered the home, demanded money and drugs, and began shooting Boatner's friends.  Boatner testified that Smith was one of the gunmen.  The State presented no other evidence linking Smith to the crime.

As part of Smith's effort for post-conviction relief, he sought and obtained files from the police investigation in the case, including the notes of Detective John Ronquillo, which were not made available to Smith during his trial.  Detective Ronquillo's notes contained numerous statements by Boatner that conflicted with his testimony, including that he "could not . . . supply a description of the perpetrators other then [sic] they were black males" and that he "could not ID anyone because [he] couldn't see faces." 

Smith argued in post-conviction proceedings in the state trial court that the State's failure to disclose these notes violated Brady v. Maryland.  The trial court denied his petition, and the Louisiana Court of Appeal and Louisiana Supreme Court denied review.  The Supreme Court granted certiorari and reversed.

The State violates Brady "if it withholds evidence that is favorable to the defense and material to the defendant's guilt or punishment." Because the State in Smith conceded that Boatner's statements were favorable to Smith, the Court's analysis focused on whether they were material to Smith's guilt.  Stating that "material" means only that "there is a reasonable probability  . . . the result of the proceeding would have been different," the Court held that the State's withholding of Boatner's testimony violated Brady.  Although eyewitness impeachment may not always be material under Brady, where, as in this case, it was the "only evidence linking Smith to the crime" and "the undisclosed statements directly contradict" the eyewitness testimony, it is  "plainly material." Smith was therefore entitled to a new trial.

Chief Justice Roberts delivered the opinion of the Court, in which Justices Scalia, Kennedy, Ginsburg, Breyer, Alito, Sotomayor, and Kagan joined.  Justice Thomas filed a dissenting opinion.

Download Opinion of the Court

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