Commonwealth, Aplt. v. Johnson, R., 713 CAP

In 1997, Roderick Johnson was convicted of two counts of first-degree murder and sentenced to death; the Commonwealth’s case relied heavily on witness George Robles linking Johnson to a .38 caliber murder weapon.
At trial Robles testified Johnson owned a .38 and confessed to taking, wiping, and discarding the gun; defense cross-examination sought to show Robles was an informant and involved in criminal activity but lacked concrete evidence to impeach him.
Post-trial, Johnson obtained a letter from Robles offering to “do anything” to get out of jail; on direct appeal this Court found that letter insufficient, standing alone, for Brady relief.
During later federal habeas proceedings in an unrelated case, the Commonwealth was ordered to produce documents concerning Robles’ relationships with police; five withheld police reports were produced showing multiple incidents suggesting Robles cooperated with police, lied to police, and engaged in criminal activity that went uncharged.
Johnson raised a Brady claim in a PCRA petition asserting the Commonwealth’s suppression of those police reports impeached Robles’ credibility; the PCRA court granted a new trial, finding the reports material and likely to have altered the verdict.
The Supreme Court of Pennsylvania affirmed, holding the withheld reports were favorable impeachment evidence and that their nondisclosure undermined confidence in the trial outcome.

Issue	Plaintiff's Argument (Commonwealth)	Defendant's Argument (Johnson)	Held
Whether withheld police reports were Brady material	Reports were not material because their contents would not have been admissible as substantive evidence	Reports were impeachment evidence that would have meaningfully impaired Robles’ credibility and affected the verdict	Held material; reports could have been used to impeach Robles and undermine confidence in the verdict
Whether nondisclosure prejudiced the defendant	Any impeachment value was insignificant in light of strong evidence of guilt	Cumulative impeachment value of reports plus Robles’ letter created a reasonable probability of a different outcome	Held prejudice established: reasonable probability the verdict would differ with disclosure
Whether admissibility is dispositive for Brady analysis	Argued admissibility (substantive use) controls materiality	Impeachment evidence need not be substantively admissible to be material under Brady	Held admissibility is not dispositive; materiality assessed by reasonable probability standard
Whether the PCRA court applied proper standard and factual findings	Contended PCRA erred in granting new trial and expanding Brady obligations	Argued PCRA properly applied Brady/Giglio/Napue standards and relied on supported factual findings	Held PCRA’s grant of a new trial affirmed; factual findings supported and legal standard correctly applied

Brady v. Maryland, 373 U.S. 83 (prosecution must disclose favorable material evidence)
Giglio v. United States, 405 U.S. 150 (nondisclosure of witness-dealings can affect credibility and requires disclosure)
Napue v. Illinois, 360 U.S. 264 (jury’s estimate of witness truthfulness can determine guilt)
Strickler v. Greene, 527 U.S. 263 (Brady suppression elements and materiality analysis)
United States v. Bagley, 473 U.S. 667 (impeachment evidence falls within Brady)
Kyles v. Whitley, 514 U.S. 419 (reasonable probability standard for materiality)
Cone v. Bell, 556 U.S. 449 (Brady materiality tied to reasonable probability of different result)
Wood v. Bartholomew, 516 U.S. 1 (inadmissible evidence not material where it would not affect cross-examination or outcome)