Aguilera v. State
2011 Iowa Sup. LEXIS 97
Iowa2011Background
- Aguilera convicted of second‑degree murder in 1997; this is his second postconviction relief application.
- Alleged Brady violation: State failed to disclose a DCI file with witness statements before trial.
- DCI file contained statements from Guido, Lopez, Reyes, Lucio, Shuver, and Zeidy Aguilera; some witnesses testified, others did not.
- District court found suppression of the full DCI file and that the statements were exculpatory but not material; dismissal followed.
- Court of appeals affirmed; this Court reverses, concluding suppression and materiality support a Brady violation.
- Statements in the file would have provided impeachment and alternative interpretations, potentially altering trial strategy and outcome.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Was there suppression of exculpatory evidence? | Aguilera | State | Yes; full DCI file suppressed, not just portions. |
| Were the suppressed statements favorable to Aguilera? | Aguilera | State | Yes; statements were exculpatory or impeachment material. |
| Was the suppressed evidence material to guilt? | Aguilera | State | Yes; cumulative impeachment and alternative theories could have changed the outcome. |
| Did suppression affect trial strategy and undermine confidence in the verdict? | Aguilera | State | Yes; suppression likely altered defense approach and trial dynamics. |
Key Cases Cited
- Brady v. Maryland, 373 U.S. 83 (U.S. 1963) (prosecution must disclose favorable evidence.)
- Harrington v. State, 659 N.W.2d 509 (Iowa 2003) (materiality requires reasonable probability of different outcome.)
- Desimone v. State, 803 N.W.2d 97 (Iowa 2011) (impeachment and exculpatory evidence fall under Brady.)
- Cornell v. State, 430 N.W.2d 384 (Iowa 1988) (exculpatory evidence not suppressed if defendant knew essential facts.)
- Strickler v. Greene, 527 U.S. 263 (U.S. 1999) (materiality defined by reasonable probability of different outcome.)
- Kyles v. Whitley, 514 U.S. 419 (U.S. 1995) (collective effect of suppressed evidence considered.)
- United States v. Bagley, 473 U.S. 667 (U.S. 1985) (impeachment and exculpatory evidence within Brady.)