Figueroa v. State
480 S.W.3d 888
Ark. Ct. App.2016Background
- Figueroa was charged with two counts of rape for the September 2, 2012 assault at a University of Arkansas parking lot.
- Trial occurred March 2–3, 2015; defense sought mistrial or continuance for discovery issues involving a second suspect and a DNA warrant.
- Prosecutor disclosed DNA evidence linking Figueroa after trial began; defense allowed to impeach credibility of the investigation.
- State faulted for failing to disclose information about a DeQueen suspect, Trinidad Abrego, and his DNA sample.
- Trial court denied the mistrial/continuance; Figueroa was convicted on both counts and sentenced to consecutive 360-month terms.
- On appeal, court reversed and remanded due to undisclosed exculpatory information impacting defense.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the failure to disclose exculpatory information was reversible discovery error | Figueroa | State | Yes; reversal remand Required |
| Whether the continuance/mistrial denial violated Brady and due-process | Figueroa | State | Yes; prejudice shown; error reversible |
| Whether undisclosed DNA-related information could have altered investigation or guilt | Figueroa | State | Yes; material information not timely disclosed |
Key Cases Cited
- Strickler v. Greene, 527 U.S. 263 (1999) (three elements of Brady violation; reasonable probability standard)
- Bagley v. United States, 473 U.S. 667 (1985) (material evidence must be favorable and suppressed; prejudice required)
- Lee v. State, 340 Ark. 504 (2000) (reasonable probability standard; timing of disclosure; impact on defense)
- Rychtarik v. State, 334 Ark. 492 (1998) (failure to disclose may be cured by continuance; trial timing)
- Lacy v. State, 2010 Ark. 388 (2010) (prosecutor must disclose information known by others acting for government)
- Bond v. State, 2015 Ark. 470 (2015) (impeachment and exculpatory evidence; applicability to Brady)