The Court ruled earlier today in a Louisiana case involving prosecutorial misconduct. The opinion in Smith v. Cain is available in Adobe .pdf format (though the link is broken at this time.) The case was argued November 8.
The Supreme Court's .pdf file of the opinion is still broken. The Smith v. Cain ruling is also available at this link.
"Supreme Court Tosses Murder Conviction for Brady Violation by New Orleans DA," byy Debra Cassens Weiss for ABA Journal.
The U.S. Supreme Court has overturned a murder conviction obtained by New Orleans prosecutors because the defense didn't receive important exculpatory evidence before the trial.
The court ruled 8-1 on behalf of Juan Smith, convicted of five murders on the strength of testimony by a single witness who identified Smith as the first gunman to come through the door during a robbery. The witness had earlier told a detective that he could not identify the perpetrators, but notes recounting the conversation were not disclosed in Smith’s trial.
Chief Justice John G. Roberts Jr. wrote the four-page majority opinion finding the conviction must be overturned because the undisclosed evidence was material under standards set by Brady v. Maryland. The lone dissent by Justice Clarence Thomas, on the other hand, spanned 19 pages. Thomas noted the witness had identified Smith after seeing his photo in an array presented by police. “This is it," the witness had said. "I’ll never forget that face.”
The ruling today in Smith v. Cain follows a Supreme Court decision last year on behalf of New Orleans prosecutors. The 2011 decision in Connick v. Thompson overturned a $14 million award to a death row inmate who alleged prosecutors withheld exculpatory blood evidence in his trial for attempted armed robbery, leading to a conviction and ramifications in a later murder case. Observers had speculated the Supreme Court granted cert in Smith v. Cain to focus on New Orleans prosecutors after the 2011 decision.
And:
The ABA had filed an amicus brief in the new case arguing that prosecutors’ ethical obligations to disclose exculpatory evidence before trial are separate from and broader than the constitutional standards established in Brady v. Maryland.
Joan Biskupic files, "Supreme Court overturns New Orleans man's murder conviction," for USA Today.
The Supreme Court ruled Tuesday that a New Orleans man's murder conviction must be reversed because prosecutors failed to reveal that the sole eyewitness to the crime had earlier said he could not identify the killer. The decision was 8-1; Justice Clarence Thomas was the lone dissent.
The Supreme Court ruled Tuesday that Juan Smith's murder conviction must be reversed. The case looked at disclosure of evidence.
The case brings to the fore problems of prosecutors' hiding evidence and the guarantee, stemming from a 1963 Supreme Court decision, that the government must turn over evidence favorable to a defendant.
"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," Chief Justice John Roberts wrote for the majority. "That is not the case here."
Earlier coverage of Smith v. Cain begins at the link.
Related posts are in the prosecutorial misconduct index. The responsibility of the state to provide exculpatory evidence to the defense was articulated in the 1963 Supreme Court ruling in Brady v. Maryland; more via Oyez.
UPDATE - "High Court Reverses Conviction in Killings," is the title of Adam Liptak's report for the New York Times.
The Supreme Court on Tuesday reversed the conviction of a New Orleans man, saying prosecutors there had withheld important evidence that his lawyers could have used in his defense.
The decision, by an 8-to-1 vote, was the latest in a series of Supreme Court decisions suggesting a pattern of prosecutorial misconduct in the Orleans Parish District Attorney’s Office. Justice Clarence Thomas dissented.
Tuesday’s case concerned Juan Smith, who was convicted of killing five people in 1995, when a group of men burst into a house in search of money and drugs. They ordered the occupants to lie down and opened fire.
Mr. Smith was the only person tried for the killings. He was convicted based solely on the eyewitness testimony of a survivor, Larry Boatner. Prosecutors presented no DNA, fingerprints, weapons or other physical evidence.
But Mr. Boatner’s testimony proved sufficient.
“He’s right there,” Mr. Boatner said at Mr. Smith’s trial, pointing at the defendant. “I’ll never forget him.”
It later emerged that prosecutors had failed to disclose reports of interviews with Mr. Boatner. In one, hours after the killings, Mr. Boatner said he could not describe the intruders except to say they were black men. Five days later, he said he had not seen the intruders’ faces and could not identify them.
Eyewitness evidence, according to recent studies and court decisions, is both unusually persuasive and unusually unreliable. Kannon K. Shanmugam, a lawyer with William & Connolly who represented Mr. Smith in the Supreme Court, told the justices in a brief that the withheld statements from Mr. Boatner “constitute the epitome of impeachment evidence.”
There was no question, Chief Justice John G. Roberts Jr. wrote for the majority, that the reports should have been turned over under Brady v. Maryland, a 1963 Supreme Court decision that requires prosecutors to provide favorable evidence to the defense. The question for the justices was only whether the failure mattered — that is, in the words of a 2009 decision, whether “there is a reasonable probability that, had the evidence been disclosed, the result of the proceeding would have been different.”
In a brisk four-page opinion in the case, Smith v. Cain, No. 10-8145, Chief Justice Roberts wrote that “Boatner’s undisclosed statements were plainly material.”
Comments