Christopher White v. Troy Steele
2017 U.S. App. LEXIS 5958
| 8th Cir. | 2017Background
- Christopher White was convicted in Missouri state court of first-degree murder, armed criminal action, and first-degree assault after eyewitness Jeffrey Shockley identified him as a shooter; Shockley testified in January 2004.
- At trial Shockley admitted he had pending state felony charges and stated on redirect that he had not received and did not expect any deal in exchange for his testimony.
- After conviction and federal habeas filing, White obtained a conflict-of-interest form and Shockley’s guilty-plea transcript suggesting prosecutors had negotiated with Shockley and that the State later paid to relocate Shockley.
- White amended his § 2254 petition (Sept. 2009) to add Brady and Napue claims alleging the State failed to disclose a deal with Shockley and failed to correct false testimony.
- The district court found the claims timely, held evidentiary hearings, found no formal or tacit agreement existed between the State and Shockley, assumed financial relocation assistance was Brady material but concluded nondisclosure was not material, and denied habeas relief; the court granted a COA on Brady and Napue.
- The Eighth Circuit affirmed, proceeding to the merits and concluding no Brady or Napue violation occurred because no agreement existed and the undisclosed relocation assistance did not undermine confidence in the verdict.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Timeliness under AEDPA §2244(d)(1)(D) | White: Brady/Napue claims timely—discovered conflict form Jan 2009; filed within 1 year | State: Form was received earlier (2007–2008); claims time-barred | Court: Unclear but declines to decide; proceeds to merits in interest of judicial economy |
| Brady — suppression of deal/understanding | White: State suppressed an agreement or understanding with Shockley promising favorable treatment for testimony | State: No agreement existed; at most an offer was rejected; thus nothing to disclose | Court: No clear error in finding no agreement; no Brady violation on this ground |
| Napue — use of false testimony | White: Shockley’s testimony that he had no deal was false; State knowingly used false testimony | State: Testimony was not false because no deal/understanding existed; State could not have knowingly used false testimony | Court: No Napue violation because testimony was not shown to be false or knowingly used as false |
| Brady — nondisclosure of financial assistance/relocation | White: The State’s payments/relocation were favorable consideration that should have been disclosed and could affect credibility | State: Payments were for safety (hotel, vouchers, relocation), not cash inducement; nondisclosure did not affect outcome | Court: Even assuming Brady materiality, nondisclosure did not undermine confidence in verdict; no Brady violation |
Key Cases Cited
- Brady v. Maryland, 373 U.S. 83 (prosecution must disclose favorable material evidence)
- Napue v. Illinois, 360 U.S. 264 (state may not use known false testimony to obtain conviction)
- Giglio v. United States, 405 U.S. 150 (agreements with witnesses bearing on credibility are Brady material)
- United States v. Rushing, 388 F.3d 1153 (8th Cir. 2004) (duty to disclose depends on existence of an agreement, not rejected offers)
- United States v. Librach, 520 F.2d 550 (8th Cir. 1975) (cash payments to witness that provide incentive to testify are Brady material)