Chamontae A. Walker & Corey D. Yates v. United States
167 A.3d 1191
| D.C. | 2017Background
- Walker and Yates were tried with Carraway for Hendy murder; Carraway pled guilty to second-degree murder.
- Walker was convicted of first-degree murder while armed, conspiracy to commit murder, and APO, plus accessory after the fact.
- Yates was convicted of second-degree murder while armed and accessory after the fact.
- The government’s theory: Walker instigated the murder, the three men were Carraway’s accomplices, and Yates aided in the crime.
- Evidence included Ebony House’s trial testimony, cousin Orlando Smith, and security camera footage; North Carolina sheltering evidence raised Brady concerns.
- Brady issues involved late disclosure of grand jury testimony about who drove Carraway and about W-10’s testimony, with contested materiality and timing findings.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of evidence for aiding and abetting Yates | Yates argued no sufficient aid or malice by him | The evidence showed Yates's encouragement and tacit approval | Evidence sufficient to sustain aiding-and-abetting conviction |
| Brady withholding of exculpatory evidence | Yates claimed late disclosure violated Brady | Disclosures were timely or not material to outcome | No Brady violation; no reasonable probability of different verdict |
| Admission of Walker’s statements as penal-interest declarations | House’s testimony about Walker’s statements should be inadmissible | Statements fit declarant‑unavailable and trustworthy criteria | Admissible under declaration against penal interest; implicit credibility findings reasonable |
| Admission of Buchanan’s interpretation of 'Let’s suit up' | Limited relevance; improper lay opinion | Reasonable lay interpretation of slang allowed | Proper lay opinion; no reversible error |
| Prosecutor’s closing argument misstatement | Timing of statements misrepresented | Argument grounded in record; permissible inference | No reversible error; argument reasonably grounded in evidence |
Key Cases Cited
- Johnson v. United States, 883 A.2d 135 (D.C. 2005) (improper reliance on non‑corroborated inferences must be guarded against)
- Creek v. United States, 324 A.2d 688 (D.C. 1974) (presence and tacit approval can support aiding and abetting)
- Laumer v. United States, 409 A.2d 190 (D.C. 1979) (requirements for credibility and trustworthiness of statements against penal interest)
- Turner v. United States, 116 A.3d 894 (D.C. 2015) ( Brady material and standard of materiality; mixed questions of fact and law)
- Zanders v. United States, 999 A.2d 149 (D.C. 2010) (late Brady disclosures and the probability of altering the verdict)
- Straker v. United States, 800 F.3d 570 (D.C. Cir. 2015) (application of Brady materiality in appellate review)
- Miller v. United States, 14 A.3d 1094 (D.C. 2011) ( Brady framework and materiality standard)
- Turner, 137 S. Ct. 1885, 137 S. Ct. 1885 (2017) (citation used within DC context for materiality discussions)