Guzman v. Secretary, Department of Corrections, 661 F.3d 602

Guzman, a death row inmate, challenges a district court grant of a new trial based on Giglio and Brady claims arising from the State's payment of $500 to Cronin, a key witness.
Cronin and Detective Sylvester allegedly testified falsely at Guzman's trial that Cronin received no benefit beyond motel housing; in fact Cronin was paid $500 and had a pending arrest warrant.
Florida courts on direct and postconviction review upheld Cronin's impeachment but treated the $500 payment as immaterial under Giglio and Brady standards.
The district court, after AEDPA review, found the state court's Giglio ruling unreasonable and granted Guzman habeas relief, ordering a new trial.
The Eleventh Circuit, applying AEDPA, agrees the state court's materiality determination was an unreasonable application of Supreme Court precedent and affirms a new trial on the Giglio claim.
This decision addresses only Guzman's Giglio claim; the Brady claim remains undecided for purposes of this opinion.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the Florida Supreme Court unreasonably applied Giglio.	Guzman asserts materiality was misapplied.	Sylvester and Cronin testimony immaterial given other evidence.	Yes; state court unreasonably applied Giglio.
Whether the undisclosed $500 reward to Cronin could have affected the verdict.	Reward created motive to lie; material to credibility.	Impeachment and corroboration outweighed any effect of the reward.	Could have affected the judgment; non-materiality rejected.
Whether the district court properly granted habeas relief under AEDPA.	State court's Giglio ruling was unreasonable; relief warranted.	AEDPA deference requires more precise reasoning and respect for state court.	District Court's grant affirmed for Giglio claim.
Whether the Giglio standard is satisfied by the combination of false testimony and lack of disclosure.	Two false statements (Cronin and Sylvester) and suppression undermine confidence.	Other evidence independently supports Guzman's guilt; false testimony was not material.	Giglio standard satisfied; new trial required.
Whether the error was harmless beyond a reasonable doubt under Brecht.	Harmlessness not satisfied given the credibility contest and key witness impact.	Impeachment and corroboration render error harmless.	Court did not resolve Brecht here; focus remains on materiality; relief granted on Giglio claim.

Brady v. Maryland, 373 U.S. 83 (1963) (federal due-process requirement to disclose favorable evidence)
Giglio v. United States, 405 U.S. 150 (1972) (materiality of witness testimony and required correction of false testimony)
Napue v. Illinois, 360 U.S. 264 (1959) (false testimony or failure to correct known false testimony violates due process)
Kyles v. Whitley, 514 U.S. 419 (1995) (materiality analysis requires considering favorable evidence in light of the whole case)
Agurs v. United States, 427 U.S. 97 (1976) (defendant not required to request favorable evidence to obtain it)
Harrington v. Richter, 131 S. Ct. 770 (2011) (AEDPA deference and 'unreasonable application' standard)
Moon v. Head, 285 F.3d 1301 (11th Cir. 2002) (presumption of correctness for state court findings; materiality is a legal question)
Davis v. Zant, 36 F.3d 1538 (11th Cir. 1994) (illustrative pre-AEDPA context for evaluating prosecutorial conduct and evidence)
Mooney v. Holohan, 294 U.S. 103 (1935) (due process requires truth-seeking and avoidance of false evidence)