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Smith v. Cain

Summarized by: 

Date Filed: November 8, 2011
Case #: (10-8145)
Louisiana State Court
Full Text Opinion: Unreported

Criminal Procedure: Whether Louisiana state courts erred when they rejected petitioner's Brady v. Maryland claims that the district attorney failed to produce evidence favorable to the accused and thus violated his due process rights.

In 1995, a group of men burst into a house and shot and killed five people. Petitioner, Juan Smith, was the only person brought to trial. Petitioner was convicted of five counts of first degree murder and sentenced to life imprisonment without parole. His sole link to the crime scene was an identification by a witness. At trial, the state failed to disclose to defense counsel numerous conflicting statements made by the witness and other potentially exculpatory evidence despite petitioner’s pretrial motion for “discovery of information necessary to a fair trial.”

Petitioner’s conviction and sentence in Louisiana state court were affirmed on direct review. The state court, after a full evidentiary hearing, also denied Petitioner’s application for post-conviction relief. The Louisiana Court of Appeals denied his application for discretionary review as did the Louisiana Supreme Court.

Smith premises his argument on Brady v. Maryland which held that suppression by prosecution of evidence favorable to an accused violates due process if the evidence is material as to the matter of guilt. Smith argues that the Orleans Parish district attorney’s office violated his due process rights because they failed to disclose a berth of favorable information including information that impeached testimony of the only witness linking Smith to the crime, information from an apparent perpetrator suggesting that Smith had not been involved in the crime and information indicating that other individuals were responsible for the shooting.