Strickler v. Greene

Supreme Court of the United States · 1999 · Federal Courts

Federal CourtsHabeas CorpusBradyProcedural DefaultBrady v. Marylandsuppressed impeachment evidencematerialitycause and prejudice

Facts

At petitioner’s capital murder trial, the Commonwealth presented Anne Stoltzfus as the only disinterested eyewitness to the abduction, and she testified in vivid detail identifying petitioner and describing him as the aggressive actor. After state proceedings ended, federal habeas discovery revealed police notes and Stoltzfus letters that seriously impeached her claimed memory and showed uncertainty, confusion, and memory reconstruction after police assistance. At least five of those documents had not been disclosed to the defense, despite the prosecutor’s open file policy and representations that the defense had been given everything known to the government. Petitioner argued that the suppressed impeachment evidence undermined both his conviction for capital murder and his death sentence.

Issue

Whether the Commonwealth’s failure to disclose impeaching Stoltzfus materials constituted a Brady violation, and whether petitioner’s failure to raise that claim in state court was excused by cause and prejudice. More specifically, the Court considered whether petitioner had cause for the procedural default and whether the suppressed evidence was material enough to establish prejudice.

Rule

A true Brady violation has three components: the evidence must be favorable to the accused, either because it is exculpatory or impeaching; the evidence must have been suppressed by the State, willfully or inadvertently; and prejudice must have ensued. Evidence is material only if there is a reasonable probability that, had it been disclosed, the result of the proceeding would have been different, meaning the undisclosed evidence must put the whole case in such a different light as to undermine confidence in the verdict. For procedural default, cause exists when an objective factor external to the defense impeded compliance, and in this context suppression of evidence, reasonable reliance on an open file policy, and the State’s confirmation that all known material had been disclosed can establish cause.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

In a murder trial in Columbus, Ohio, the State’s case depended heavily on a store clerk, Maya Benton, who testified with certainty that she saw Devin Cole force the victim into a car. Years later, habeas counsel found police interview notes showing that Maya initially said she was confused, had only a brief glimpse, and was unsure whether she could identify anyone.

If Devin argues that the undisclosed notes satisfy the first component of a Brady claim, what is the best answer?

Explanation. A true Brady claim requires favorable evidence, suppression, and resulting prejudice. Favorable evidence includes both exculpatory and impeaching material. Under the majority opinion, notes showing uncertainty, confusion, or reconstructed memory can be favorable because they would undermine a witness’s confident trial testimony.