In Re: Ronald Seastrunk
236 So. 3d 509
| La. | 2017Background
- Victim Christopher Hoffpauir was murdered in June 2010; Kristyn Hoffpauir gave multiple, conflicting statements implicating Justin Sizemore and describing different accounts of the shooter’s actions.
- Kristyn pleaded guilty and agreed to testify against Sizemore; prosecutors (including respondent Ronald Seastrunk and ADA Scott Westerchil) divided responsibilities but did not designate a single "first chair."
- Detective Ortiz obtained a hearsay report from defense witness Jody Thibeaux that Kristyn once kept a .22 revolver and had threatened to kill her mother; that information was not initially placed in the police report or disclosed to defense.
- Undisclosed information (Westerchil’s interview notes and Ortiz’s interview report) led to mistrials in the first two Sizemore trials; the third trial produced a conviction affirmed on appeal.
- ODC charged Seastrunk with violating Rule 3.8(d) for failing to disclose exculpatory evidence; hearing committee and disciplinary board found a violation and recommended a public reprimand.
- The Louisiana Supreme Court held Rule 3.8(d) is coextensive with Brady materiality, concluded ODC failed to prove a Rule 3.8(d) violation by clear and convincing evidence, and dismissed all charges against Seastrunk.
Issues
| Issue | Plaintiff's Argument (ODC) | Defendant's Argument (Seastrunk) | Held |
|---|---|---|---|
| Whether Rule 3.8(d) imposes broader disclosure duties than constitutional Brady materiality | Rule 3.8(d) requires disclosure of otherwise exculpatory evidence even if not Brady‑material; Jordan supports strict ethical duty | Rule 3.8(d) aligns with Brady; disclosure must be limited by materiality to avoid inconsistent/overbroad obligations | Rule 3.8(d) and Brady are coextensive; materiality standard applies (Court rejects ODC's broader rule) |
| Whether respondent violated Rule 3.8(d) by failing to disclose Thibeaux’s hearsay report about Kristyn’s gun | Thibeaux’s statement undermined Kristyn’s credibility and was material to guilt; should have been disclosed | Statement was remote, hearsay, not exculpatory or material; disclosure decision was reasonable and supervised | ODC failed to meet clear-and-convincing proof of a Rule 3.8(d) violation; charges dismissed |
| Whether Rule 5.2(b) safe-harbor (reliance on supervisory lawyer) shields respondent | ODC argued no reasonable arguable question of duty existed, so reliance was not protected | Seastrunk argued he reasonably followed District Attorney Skinner’s decision, invoking Rule 5.2(b) | Court did not need to resolve because it found no proved Rule 3.8(d) violation and pretermitted Rule 5.2(b) analysis |
Key Cases Cited
- Brady v. Maryland, 373 U.S. 83 (holding suppression of material favorable evidence violates due process)
- United States v. Bagley, 473 U.S. 667 (adopting "reasonable probability" materiality test for Brady)
- Kyles v. Whitley, 514 U.S. 419 (discussing prosecutor’s duty to disclose and materiality under Brady)
- In re: Jordan, 913 So.2d 775 (La. 2005) (disciplinary case involving nondisclosure; Court previously noted Rule 3.8(d) is similar to Brady)
- State v. Cousin, 710 So.2d 1065 (La. 1998) (underlying criminal case in Jordan where withheld statement was deemed obviously exculpatory)