Anthony Juniper v. David Zook
876 F.3d 551
| 4th Cir. | 2017Background
- Anthony Juniper was convicted and sentenced to death for four murders in Norfolk, VA; physical evidence (knife blade with his thumbprint; knife handle with his DNA; cigarette butt with his DNA) connected him to the scene, but no gun was recovered.
- Post-conviction, investigative notes revealed that Norfolk detective R. Glenn Ford (later convicted of corruption) had not disclosed notes recounting neighbor Wendy Roberts’s and her son Jason’s statements that they heard sounds like gunshots after 1:00 p.m. and that Wendy saw a man (not Juniper) leave in a large four‑door car.
- Roberts’s contemporaneous notes and a photo array showing Juniper (which Roberts reportedly did not pick) were not provided to Juniper’s trial counsel; the Commonwealth resisted disclosure during state and federal habeas proceedings.
- Juniper raised a Brady claim in federal habeas under 28 U.S.C. § 2254, asserting suppression of exculpatory/impeaching evidence (Roberts materials) that pointed to a different suspect and a later time frame for the murders.
- The district court ordered limited discovery, received some investigative notes and affidavits from prosecutors/detectives, concluded the Roberts materials were favorable and suppressed but not material, denied an evidentiary hearing, and dismissed the § 2254 petition as to Brady.
- The Fourth Circuit vacated that portion of the district court’s decision and remanded, holding the district court abused its discretion by resolving materiality and credibility without an evidentiary hearing given the plausibility of Juniper’s Brady allegations and the need to assess witness credibility in person.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether suppression of Roberts materials violated Brady | Juniper: Roberts’s statements and failed photo‑identification were favorable, suppressed, and material because they pointed to another suspect and a later time, undermining key eyewitnesses and timeline | Commonwealth: Roberts statements were inconsistent with 911/event chronology and eyewitness testimony; thus not "material" and not required to be disclosed | Vacated district court denial of hearing; remanded for evidentiary hearing to assess credibility and materiality — district court erred by deciding materiality on the record alone |
| Whether an evidentiary hearing was required in federal habeas | Juniper: Diligently pursued discovery in state court; newly revealed evidence and inadequate state fact‑finding justify an evidentiary hearing under Townsend and Rule 12(b)(6) plausibility standard | Commonwealth: No good cause for more discovery/hearing; evidence would not change result because of strong forensic links (knife, DNA) and January 16 timeline | Held: Juniper alleged facts sufficient under Rule 12(b)(6) and Townsend factors; district court abused discretion by denying hearing |
| Whether Roberts materials were exculpatory/impeaching and suppressed | Juniper: Materials impeach prosecution witnesses and suggest another perpetrator/time, thus exculpatory/impeaching and were not disclosed | Commonwealth: Materials inconsistent and therefore not Brady material; prosecution produced all required discovery | Held: Court agreed materials were favorable and suppressed; materiality unresolved without hearing |
| Whether suppressed evidence was "material" under Kyles/Strickler | Juniper: When assessed collectively and viewing credibility in his favor, suppressed Roberts evidence could reasonably undermine confidence in verdict | Commonwealth: Forensic evidence (knife/DNA) and 12:44 p.m. 911 call fix timeline such that Roberts evidence could not create reasonable probability of different result | Held: Court found district court applied wrong standard, improperly credited prosecution witnesses and failed to subtract impeachment value; remand for hearing to decide materiality and possible further discovery |
Key Cases Cited
- Brady v. Maryland, 373 U.S. 83 (1963) (suppression of favorable evidence violates due process)
- Kyles v. Whitley, 514 U.S. 419 (1995) (materiality standard: evidence that could put case in different light and undermine confidence)
- Strickler v. Greene, 527 U.S. 263 (1999) (reasonable‑probability materiality test explained)
- Townsend v. Sain, 372 U.S. 293 (1963) (factors for when federal evidentiary hearing is required)
- Williams v. Taylor, 529 U.S. 420 (2000) (diligence standard for state‑court fact development)
- Banks v. Dretke, 540 U.S. 668 (2004) (Brady components and relation to procedural default)
- Schriro v. Landrigan, 550 U.S. 465 (2007) (evidentiary hearing standards in habeas)
- Wolfe v. Clarke (Wolfe II), 691 F.3d 410 (4th Cir. 2012) (Brady disclosure duties and rebukes for nondisclosure)