Jordan v. State, 343 S.W.3d 84

Douglas Jordan was convicted of second degree murder and sentenced to 23 years in prison.
Post-conviction relief was granted in part for suppressed evidence but found not material to defense; on appeal, Jordan contends Brady violations and related issues.
Evidence allegedly suppressed includes Exhibit 9 (knife found near the victim) and a March 13 case memo; defense argues these were favorable and material.
State allegedly maintained an open-file policy; defense claims it relied on this policy to obtain discovery, which allegedly did not include the knife or memo.
Trial counsel testified he was unaware of the knife and memo, and that disclosure could have changed defense strategy or cross-examination.
On review, the court concluded the state violated Brady by withholding favorable and material evidence, remanding for a new trial.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Did the state withhold favorable, material Brady evidence?	Jordan contends the knife and March 13 memo were favorable and suppressed.	State argues open-file policy and lack of suppression, or lack of materiality.	Yes; suppression of favorable and material Brady evidence required reversal and new trial.
Should the materiality prong be judged under Brady rather than sufficiency standards?	Materiality was misapplied using sufficiency standards.	No misapplication; court properly evaluated materiality.	Brady materiality applies; insufficient to discuss under sufficiency standards.
Did suppression violate Article I, sections 1 and 2 of the Tennessee Constitution?	Jordan claims broader constitutional violation beyond Brady.	State asserts no broader constitutional violation is necessary to reverse.	Court declines to determine broader constitutional question; reversal on Brady grounds suffices.
Was trial counsel ineffective for failing to discover suppressed Brady evidence?	Ineffective assistance for not uncovering withheld materials.	If Brady violated, issue moot; no independent ineffective assistance result.	No independent finding of ineffective assistance; reversed on Brady grounds.

Brady v. Maryland, 373 U.S. 83 (1963) (prosecution's suppression of favorable evidence violates due process)
Bagley v. United States, 473 U.S. 667 (1985) (favors exculpatory and impeachment evidence under Brady)
Kyles v. Whitley, 514 U.S. 419 (1995) (materiality judged by reasonable probability of different outcome; cumulative evidence)
Strickler v. Greene, 527 U.S. 263 (1999) (open file policy; defense reliance; disclosure obligations)
Johnson v. State, 38 S.W.3d 52 (Tenn. 2001) (definition of favorable information and duty to disclose)
Branch v. State, 469 S.W.2d 533 (Tenn.Crim.App.1969) (knife found at scene and suppression of origin evidence; Brady relevance)
State v. Walker, 910 S.W.2d 381 (Tenn. 1995) (statements on Brady and discovery in Tennessee context)