LaCaze v. Warden Louisiana Correctional Institute for Women
2011 U.S. App. LEXIS 13242
| 5th Cir. | 2011Background
- LaCaze was convicted in Louisiana state court of second-degree murder and sentenced to life without parole.
- Robinson, a long-time friend of the victim and LaCaze's extramarital lover, testified at trial after pleading to manslaughter with a forty-year sentence.
- LaCaze's discovery motion alleged the State failed to disclose an understanding that Robinson’s son would not be prosecuted in exchange for his testimony.
- The State disclosed Robinson’s plea to manslaughter and his sentence, but did not disclose the parental-protection assurance to Robinson.
- Louisiana courts held the undisclosed assurance relevant to credibility but ultimately found it immaterial in light of the plea and corroboration.
- The district court and Fifth Circuit denied post-conviction relief, leading to habeas review under AEDPA and the two certifications of appealability.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Brady materiality of undisclosed deal | LaCaze: non-disclosed assurance to Robinson was material to credibility. | Leger/States: knowledge of plea to manslaughter rendered it immaterial. | Brady material was material; failure to disclose violated due process. |
| Impartial jury under Ross v. Oklahoma | LaCaze contends jurors were influenced by undisclosed witness bias. | State argues no structural defect and evidence otherwise supported conviction. | Court treats Brady ruling as dispositive; remand for writ with conditions. |
Key Cases Cited
- Napue v. Illinois, 360 U.S. 264 (1959) (witness credibility and promises affect impeachment materiality)
- Giglio v. United States, 405 U.S. 150 (1972) (any understanding affecting credibility is material)
- Tassin v. Cain, 517 F.3d 770 (5th Cir. 2008) (promises or understandings about leniency can render testimony material)
- Kyles v. Whitley, 514 U.S. 419 (1995) (materiality relies on effect on verdict, not certainty of acquittal)
- Mahler v. Kaylo, 537 F.3d 494 (5th Cir. 2008) (materiality assessment in Brady claims requires nuanced analysis)
- Rocha v. Thaler, 619 F.3d 387 (5th Cir. 2010) (Brad[y] material depends on overall strength of impeachment evidence)
- Moody v. Quarterman, 476 F.3d 260 (5th Cir. 2007) (AEDPA review and factual deferential standards)