Canales-Yanez v. State, 244 A.3d 1096

On June 5, 2017 two high‑school seniors were shot to death after being lured to a cul‑de‑sac; Jose Canales‑Yanez was convicted after an eight‑day bench trial of two counts of first‑degree murder, conspiracy, armed robbery, and related firearm counts.
One prosecution witness, Victoria Kuria, first told police she knew nothing; months later she gave a different, inculpatory account after police re‑contacted her and after detectives interviewed her mother and stepfather (the “Bells”).
The State did not disclose the recorded October 10, 2017 interview of the Bells (in which detectives suggested Kuria could be prosecuted for lying) until after trial; defense moved for a new trial under Brady v. Maryland alleging that the late disclosure was material impeachment evidence.
The circuit court denied the motion, finding the recording immaterial to the verdict; the Court of Special Appeals affirmed but adopted a deferential “patently unreasonable” standard for bench‑trial Brady rulings.
The Maryland Court of Appeals granted certiorari, rejected the new deferential standard, applied de novo Brady review using Bagley/Brady and the Wilson factors, and held the undisclosed recording was not material; it affirmed denial of a new trial.

Issue	Canales‑Yanez (Petitioner) Argument	State Argument	Held
Proper standard of review for a trial court’s Brady determination after a bench trial	Defer to the trial judge; Court of Special Appeals’ “patently unreasonable” standard appropriate because the judge was the factfinder	Brady raises a constitutional question; Ware requires de novo review regardless of bench or jury trial	De novo review required; Court rejects the “patently unreasonable” standard
Whether the undisclosed Bells interview was Brady‑material impeachment evidence	The recording shows detectives threatened prosecution or promised leniency, inducing Kuria to change her story — material bias impeachment that would likely affect the verdict	The interview was cumulative, Kuria was already impeached (lied in first interview, received housing assistance), she was not central, and other strong circumstantial/forensic evidence made the case not close	Not material under Brady/Bagley and Wilson factors; no Brady violation; new trial properly denied
Whether nondisclosure impaired defense strategy (witnesses, jury vs judge)	Had defense known, it could have questioned the Bells, Mitchell, or Foogle and might have chosen a jury trial	Speculative; the defense already had facts to pursue those lines; the jury‑trial argument was not preserved and was unsubstantiated	Speculative effects on strategy failed to show a reasonable probability of a different outcome; not material

Brady v. Maryland, 373 U.S. 83 (1963) (prosecutor must disclose material exculpatory and impeachment evidence)
Giglio v. United States, 405 U.S. 150 (1972) (Brady principles apply to impeachment evidence of witness deals or promises)
United States v. Bagley, 473 U.S. 667 (1985) (evidence is material if it creates a reasonable probability of a different result)
Ware v. State, 348 Md. 19 (1997) (Brady determinations are constitutional questions reviewed de novo)
Wilson v. State, 363 Md. 333 (2001) (six‑factor framework for assessing materiality of withheld impeachment evidence)
Yearby v. State, 414 Md. 708 (2010) (defines reasonable probability as a substantial possibility)
Harris v. State, 407 Md. 503 (2009) (application of Wilson factors and materiality analysis)
Conyers v. State, 367 Md. 571 (2002) (impeachment materiality where witness was central to linking defendant to crime)
Strickler v. Greene, 527 U.S. 263 (1999) (Brady framework and burden allocation)