Brooks v. Tennessee
2010 U.S. App. LEXIS 24025
6th Cir.2010Background
- Brooks was convicted in Tennessee state court of first-degree felony murder, especially aggravated robbery, theft over $1,000, and setting fire to personal property, and was sentenced to life plus 27 years.
- On federal habeas review, Brooks alleged prosecutorial misconduct: failure to disclose impeaching evidence about jailhouse informant Nelson, use of an informant to elicit a confession, and presentation of alleged false testimony at trial.
- Nelson testified at Brooks's trial; he claimed a jailhouse confession by Brooks, and his credibility was a central issue at trial.
- Postconviction proceedings revealed Nelson had mental illness and a criminal history, and that Brooks’s lawyers argued the State failed to disclose these impeaching factors.
- At federal evidentiary hearings, Nelson recanted, and Brooks claimed prosecutorial misconduct and failure to disclose impeachment and other favorable evidence; the district court evaluated credibility and materiality under Brady/Napue/Giglio.
- The district court denied relief, and the Sixth Circuit affirmed, concluding the asserted Brady/Napue/Giglio issues were not material to vitiate the trial.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Did the nondisclosure of Nelson impeachment materials violate Brady? | Brooks | State | No reversible Brady materiality; undisclosed items not material overall. |
| Was Agent Phillips's false-testimony about fingerprints a Brady-Napue-Giglio violation? | Brooks | State | Not material; testimony not reasonably likely to affect the verdict. |
| Did Nelson's recantation and the informant issue implicate Brooks's Sixth Amendment right to counsel? | Brooks | State | District court credibility finding stands; no prosecutorial misconduct established. |
| Did procedural default bar these claims, and did cause-and-prejudice excuse it? | Brooks | State | Claims defaulted; district court properly denied relief; no sufficient cause or prejudice shown. |
Key Cases Cited
- Brady v. Maryland, 373 U.S. 83 (1963) (duty to disclose material favorable evidence)
- Napue v. Illinois, 360 U.S. 264 (1959) (prosecutor's knowledge of false testimony; duty to correct false testimony)
- Giglio v. United States, 405 U.S. 150 (1972) (materiality of impeachment evidence and informant testimony)
- Kyles v. Whitley, 514 U.S. 419 (1995) (materiality requires reasonable probability of a different outcome)
- Strickler v. Greene, 527 U.S. 263 (1999) ( Brady materiality and suppression analysis; mixed questions of law and fact)