Smith v. Cain
January 10, 2012
Case #: 10-8145
Roberts, C.J. delivered the opinion of the Court in an 8-1 decision; Thomas, J. filed a dissenting opinion.
Full Text Opinion: http://www.supremecourt.gov/opinions/11pdf/10-8145.pdf
Criminal Procedure: Failure to disclose material evidence violates Brady and may require reversal of conviction.
Smith was convicted of first-degree murder on the testimony of a single eyewitness. During postconviction proceedings, Smith received police files containing witness statement’s contradicting his own. Smith argued failure to disclose those statements violated Brady v. Maryland. The trial court rejected Smith’s Brady claim, the Appeals Court and Lousiana Supreme Court denied review.
Under Brady, evidence is material if there is a “reasonable probability that, had the evidence been disclosed, the result of the proceeding would have been different.” Cone v. Bell. Evidence to impeach a witness may not be material if the State’s other evidence is strong enough to sustain confidence in the verdict. The Supreme Court held that the eyewitness’s undisclosed testimony contradicted his testimony and the statements were plainly material. The State’s failure to disclose the evidence violated Brady.