ALONZO R. VAUGHN and CARL S. MORTON v. UNITED STATES
93 A.3d 1237
| D.C. | 2014Background
- Morton and Vaughn were convicted of aggravated assault and assault on a police officer for an incident at the D.C. Jail involving corrections officers and an inmate attack on Sergeant White and Deon Spencer.
- The government relied on video stills and corrections officers’ identifications, notably Officer Childs, to identify Morton and Vaughn.
- The defense learned that Officer Childs had a credibility issue stemming from a separate DOC Internal Affairs investigation showing false reporting and a demotion, information the government did not disclose.
- The government later filed an ex parte five-page excerpt of the OIA Final Report in limine, omitting material appendices and the report’s findings of false reporting and discipline.
- Trial proceeded without the full OIA Final Report; three months after trial the defense obtained the ten-page report and the investigator’s affidavit, revealing the discipline and the scope of the investigation.
- The court ultimately reversed Morton’s convictions on Brady grounds and remanded for a new trial, while reversing Vaughn’s aggravated assault conviction on a plain-error theory related to an incorrect jury instruction; other issues were decided in favor of the government or moot on remand.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Brady disclosure failure | Morton; nondisclosure of OIA Final Report impeaches credibility | Morton and Vaughn; government withheld favorable information | Brady violation; remand for Morton; Vaughn relief denied on Brady grounds |
| Timeliness and completeness of Brady disclosure | Morton and Vaughn; five-page excerpt was incomplete and untimely | Government argued it disclosed Brady material in limine | Disclosure not timely or complete; Brady violated |
| Jury instruction error (aiding and abetting) | Vaughn; aiding-and-abetting instruction mis-stated standard | Government concedes error but argues no prejudice | Plain error; Vaughn’s aggravated assault conviction reversed |
| Identification testimony under Sanders | Morton and Vaughn; lay identifications lacked adequate foundation | Court did not abuse Sanders ruling | Identification testimony sustained under Sanders; no reversal for this issue |
| Ineffective assistance of counsel | Vaughn; trial counsel deficient for not pursuing witnesses | Counsel's strategic choices were reasonable | Affirmed trial court’s denial of ineffective assistance claim |
Key Cases Cited
- Brady v. Maryland, 373 U.S. 83 (U.S. 1963) (duty to disclose favorable information prior to trial)
- Bagley v. United States, 473 U.S. 667 (U.S. 1985) (impeaching evidence is exculpatory; materiality test for Brady)
- Giglio v. United States, 405 U.S. 150 (U.S. 1972) (impeachment evidence includes witness’s credibility fell within Brady scope)
- Kyles v. Whitley, 514 U.S. 419 (U.S. 1995) (prosecutor’s Brady duty; cumulative unreliability standard)
- Miller v. United States, 14 A.3d 1094 (D.C. 2011) (Brady analysis; timely, complete, usable disclosures; materiality)
- Zanders v. United States, 999 A.2d 164 (D.C. 2010) (definitions of favorable information and duty to disclose)