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Criminal Procedure Keyed to Dressler
United States v. Agurs
Citation:427 U.S. 97, 96 S.Ct. 2392, 49 L.Ed.2d 342.
The defendant and James Sewell checked into a motel together as man and wife. Sewell was wearing a bowie knife in a sheath, carried another knife in his pocket, and $360 in cash on his person. About 15 minutes later, three motel employees heard the defendant screaming for help. They discovered Sewell on top of the defendant, struggling for possession of the bowie knife. The employees separated the two and called the police. The defendant left before they arrived. Sewell was dead on arrival at the hospital.
She surrendered to the police the next morning. She was given a physical examination which revealed no cuts or bruises of any kind, except needle marks on her upper arm. An autopsy of Sewell disclosed that he had several deep stab wounds in his chest and abdomen, and a number of slashes on his arms and hands, characterized as defensive wounds.
At trial, it was suggested that the parties had completed an act of intercourse, that Sewell had then gone to the bathroom down the hall, and that the struggle occurred upon his return. The contents of his pockets were on the dresser and no money was found. The jury may have inferred that the defendant took Sewell’s money and that the fight started when Sewell re-entered the room and saw what she was doing. The defendant offered no evidence but argued that she was acting in self-defense. The jury found her guilty and she was convicted of second-degree murder.
Three months later, the defense counsel filed a motion for a new trial asserting that he had discovered that Sewell had a prior criminal record that would have further evidenced his violent character and that the prosecutor had failed to disclose this information to the defense. The Government opposed the motion, arguing that there was no duty to report Sewell’s prior record to the defense in the absence of an appropriate request, that the evidence was readily discoverable in advance of trial, and that it was not material.
The District Court denied the motion. The Court of Appeals reversed. It held that the evidence was material, and that its nondisclosure required a new trial because the jury might have returned a different verdict if the evidence had been received.
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