Danforth, Warden v. Chapman
297 Ga. 29
Ga.2015Background
- Justin W. Chapman was convicted (arson and felony murder) for a 2006 fire; this Court previously affirmed his conviction.
- Chapman filed a habeas petition alleging ineffective assistance of trial and appellate counsel, Brady/Giglio violations, Crawford violations, prosecutorial misconduct, and actual innocence.
- The habeas court granted relief, finding three Brady/Giglio violations and a Crawford violation, and that appellate counsel was ineffective for failing to investigate and raise those issues on appeal.
- Central undisclosed evidence: (1) an August 2, 2006 video of witness Joseph White’s interview with the prosecutor suggesting White sought help for his own charges in exchange for information; (2) statements by inmate William Liner showing he did not hear Chapman confess and that White was seeking help, which the prosecutor obtained but did not disclose and then cancelled Liner’s production; (3) a missing page from a faxed cover letter from White revealing he wanted to "hold off" before giving his statement—material impeachment evidence.
- White was the sole witness who testified that Chapman confessed; the undisclosed materials would have impeached White’s credibility and created a reasonable probability of a different outcome.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Did prosecution suppress Brady/Giglio material that harmed due process? | Chapman: prosecution suppressed impeachment evidence (video, Liner statements, missing fax page) that was favorable and material. | Warden: no reversible error; other objections (e.g., post-hearing brief denial) and remaining claims are meritless or moot. | Court: Grant of habeas relief affirmed; suppression violated Brady/Giglio and warranted new trial. |
| Was defense denied ability to impeach Joseph White? | Chapman: undisclosed evidence contradicted White’s testimony about timing and motive, undercutting his credibility. | Warden: not contended successfully; record shows nondisclosure. | Court: Nondisclosures deprived Chapman of full cross-examination; impeachment material was favorable and material. |
| Was appellate counsel ineffective for failing to raise these issues? | Chapman: appellate counsel failed to investigate and raise Brady/Crawford on direct appeal. | Warden: argued against relief (no successful challenge). | Court: Habeas court found appellate counsel ineffective; Chapman entitled to relief (appellate cross-appeal dismissed as moot). |
| Were other alleged habeas errors preserved or dispositive? | Chapman: raised additional claims but habeas court did not reach them. | Warden: remaining allegations moot if new trial granted. | Court: Remaining Warden arguments are moot because new trial ordered; affirmed grant of writ. |
Key Cases Cited
- Brady v. Maryland, 373 U.S. 83 (establishes prosecution duty to disclose favorable material evidence)
- Giglio v. United States, 405 U.S. 150 (impeachment evidence and deals with witness promises/benefits)
- Crawford v. Washington, 541 U.S. 36 (confrontation clause standards for testimonial statements)
- Walker v. Johnson, 282 Ga. 168 (Brady standard application in Georgia)
- Schofield v. Palmer, 279 Ga. 848 (Brady/Giglio discussion)
- Gonella v. State, 286 Ga. 211 (impeachment evidence and cross-examination rights)
- Chapman v. State, 290 Ga. 631 (prior direct-appeal affirmance of Chapman’s conviction)
- Jackson v. State, 309 Ga. App. 796 (materiality of impeachment evidence)
