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Criminal Procedure Keyed to Dressler
Smith v. Cain
Citation:565 U.S. 73, 132 S.Ct. 627, 181 L.Ed.2d 571.
The defendant was charged with killing five people during an armed robbery. At the defendant’s trial, a single witness, Larry Boatner, linked the defendant to the crime. Boatner testified that he was socializing at a friend’s house when the defendant 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. He claimed that he had been face to face with the defendant during the initial moments of the robbery. No other witnesses and no physical evidence implicated the defendant in the crime.
The jury convicted the defendant of five counts of murder. The defendant obtained files from the police investigation of his case, including those of the lead detective. The detective’s notes contain statements by Boatner that conflict with his testimony identifying the defendant as a perpetrator. The notes from the night of the murder state that the defendant could not describe the perpetrators. The detective also made a handwritten account of a conversation he had with Boatner five days after the crime, in which Boatner said that he couldn’t see faces and that he could not identify any of the perpetrators of the murder.
The defendant requested that his conviction be vacated, arguing that the prosecution’s failure to disclose the detective’s notes violated this Court’s decision in Brady v. Maryland. The state trial court rejected Smith’s Brady claim, and the Louisiana Court of Appeal and Louisiana Supreme Court denied review.
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