Opinion · Supreme Court of the United States
Smith v. Cain
132 S. Ct. 627
- Type
- Opinion
- Court
- Supreme Court of the United States
- Jurisdiction
- Federal
- Date
- 2012-01-10
- Topic
- general
holding that “[e]vidence qualifies as material when there is any reasonable likelihood it could have affected the judgment of the jury” | holding that a witness’s inconsistent statements were subject to disclosure notwithstanding government’s “argument ... that the jury could have disbelieved [the] undisclosed statements” | holding that, where an eyewitness’s “testimony was the only evidence linking [the defendant] to the crime,” the eyewitness’s undisclosed prior inconsistent statements “were plainly material” | holding that notes from the investigating investigator that the only eyewitness could not describe the perpetrator was material | holding that evidence is material where it undermines "the only [testimony] linking [defendant] to the crime" (emphasis omitted) | holding that notes from the investigating investigator that the only eyewitness could not describe the perpetrator was material | holding that notes from the investigating investigator that the only eyewitness could not describe the perpetrator was material | holding that the undisclosed statements of an eyewitness were “plainly material” where the eyewitness’s testimony was the only evidence linking the defendant to the crime and his undisclosed statement directly contradicted his trial testimony | observing that the withheld evidence is material under Brady if "there is a reasonable probability that, had the evidence been disclosed, the result of the proceeding would have been different" (emphasis added | finding that withheld witness impeachment evidence was enough to trigger “reasonable probability” of a different result because witness’s “testimony was the only evidence linking Smith to the crime” | noting that evidence is material under Brady “when there is a reasonable probability that, had the evidence been disclosed, the result of the proceeding would have been different” | declining to consider additional arguments after holding that habeas relief was appropriate on the basis of one of petitioner’s Brady arguments | finding Brady violation in pros- ecution’s failure to disclose police notes that im- peached only eyewitness | finding materiality on a Brady claim where a key witness’s testimony was the only evidence linking the defendant to the crime | “[O]bserv[ing] that evidence impeaching an 23 eyewitness may not be material if the State’s other evidence is strong enough to sustain confidence in the verdict.” | reversing denial of postconviction relief where undisclosed detective notes reflected eyewitness’ uncertainty about identity of perpetrators of murder | finding Brady violation in prosecution’s failure to disclose police notes that impeached only eyewitness | “[O]bserv[ing] that 15 evidence impeaching an eyewitness may not be material if the State’s other evidence is strong 16 enough to sustain confidence in the verdict.” | “[O]bserv[ing] that evidence impeaching an eyewitness 17 may not be material if the State’s other evidence is strong enough to sustain confidence 18 in the verdict.” | applying the same “reasonable probability” standard in the context of a Brady violation and concluding that, even though “the jury could have disbelieved” evidence contrary to the non-disclosed evidence, the Court had “no confidence that it would have done so” | applying the same "reasonable probability" standard in the context of a Brady violation and concluding that, even though "the jury could have disbelieved" evidence contrary to the nondisclosed evidence, the Court had "no confidence that it would have done so" | eyewitness “testimony was the only evidence linking [the petitioner] to the crime”, and, therefore, the undisclosed statements contradicting this testimony were “plainly material” | "We have observed that evidence impeaching an eyewitness may not be material if the State's other evidence is strong enough to sustain confidence in the verdict.” | evidence impeaching prosecutor’s eyewitness testimony was “plainly material” when that eyewitness test
Citator
- Cited by
- 170 opinions
delivered the opinion of the Court.
The State of Louisiana charged petitioner Juan Smith with killing five people during an armed robbery. At Smith’s trial a single witness, Larry Boatner, linked Smith to the crime. Boatner testified that he was socializing at a friend’s house when Smith and two other gunmen entered the home, demanded money and drugs, and shortly thereafter began shooting, resulting in the death of five of Boatner’s friends. In court Boatner identified Smith as the first gunman to come through the door. He claimed that he had been face to face with Smith during the initial moments of the robbery. No other witnesses and no physical evidence implicated Smith in the crime.
The jury convicted Smith of five counts of first-degree murder. The Louisiana Court of Appeal affirmed Smith’s conviction. State v. Smith, 797 So. 2d 193 (2001). The Louisiana Supreme Court denied review, as did this Court. 2001-2416 (La. 9/13/02), 824 So. 2d 1189; 537 U. S. 1201 (2003).
Smith then sought postconviction relief in the state courts. As part of his effort, Smith obtained files from the police investigation of his case, including those of the lead investigator, Detective John Ronquillo. Ronquillo’s notes contain
Smith requested that his conviction be vacated, arguing, inter alia, that the prosecution’s failure to disclose Ronquil-lo’s notes violated this Court’s decision in Brady v. Maryland, 373 U. S. 83 (1963). The state trial court rejected Smith’s Brady claim, and the Louisiana Court of Appeal and Louisiana Supreme Court denied review. We granted cer-tiorari, 564 U. S. 1004 (2011), and now reverse.
Under Brady, 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. See 373 U. S., at 87. The State does not dispute that Boat-ner’s statements in Ronquillo’s notes were favorable to Smith and that those statements were not disclosed to him. The sole question before us is thus whether Boatner’s statements were material to the determination of Smith’s guilt. We have explained that “evidence is ‘material’ within the meaning of Brady when there is a reasonable probability that, had the evidence been disclosed, the result of the proceeding would have been different.” Cone v. Bell, 556 U. S. 449, 469-470 (2009). A reasonable probability does not mean that the defendant “would more likely than not have received a different verdict with the evidence,” only that the likelihood of a different result is great enough to “undermine[] confidence in the outcome of the trial.” Kyles v.
We have observed that evidence impeaching an eyewitness may not be material if the State’s other evidence is strong enough to sustain confidence in the verdict. See United States v. Agurs, 427 U. S. 97,112-113, and n. 21 (1976). That is not the case here. Boatner’s testimony was the only evidence linking Smith to the crime. And Boatner’s undisclosed statements directly contradict his testimony: Boatner told the jury that he had “[n]o doubt” that Smith was the gunman he stood “face to face” with on the night of the crime, but Ronquillo’s notes show Boatner saying that he “could not ID anyone because [he] couldn’t see faces” and “would not know them if [he] saw them.” App. 196,200, 308. Boatner’s undisclosed statements were plainly material.
The State and the dissent advance various reasons why the jury might have discounted Boatner’s undisclosed statements. They stress, for example, that Boatner made other remarks on the night of the murder indicating that he could identify the first gunman to enter the house, but not the others. That merely leaves us to speculate about which of Boatner’s contradictory declarations the jury would have believed. The State also contends that Boatner’s statements made five days after the crime can be explained by fear of retaliation. Smith responds that the record contains no evidence of any such fear. Again, the State’s argument offers a reason that the jury could have disbelieved Boat-ner’s undisclosed statements, but gives us no confidence that it would have done so.
The police files that Smith obtained in state postconviction proceedings contain other evidence that Smith contends is both favorable to him and material to the verdict. Because we hold that Boatner’s undisclosed statements alone suffice to undermine confidence in Smith’s conviction, we have no need to consider his arguments that the other undisclosed evidence also requires reversal under Brady.
It is so ordered.