Lawson v. State
2010 WY 145
Wyo.2010Background
- Investigation began January 2008 of suspected drug activity at Lawson residence in Cheyenne; ongoing surveillance linked Lawson to others involved in trafficking.
- Confidential informants Plavsik and an undisclosed CI2 implicated Torres and Lawson in selling cocaine/methamphetamine from the residence.
- Search of the residence on April 1, 2008 revealed drugs under the bed, including cocaine and methamphetamine, and items of drug paraphernalia.
- Lawson was charged with four counts of possession with intent to deliver and possession; defense demanded disclosure of exculpatory/impeachment evidence.
- During trial, key defense witnesses included Torres and Plavsik; Bolton testified inconsistently; defense sought to impeach Giatroudakis’s credibility.
- Post-trial, Lawson argued State withheld exculpatory material and solicited false testimony; district court denied new-trial motions; Lawson appealed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Brady violation: was exculpatory evidence suppressed and material to the defense? | Lawson asserts suppression of exculpatory materials. | State argues no material suppression; insufficient impact. | No material Brady violation; cumulative evidence did not undermine confidence in verdict. |
| Prosecutorial misconduct: did prosecutor solicit false testimony? | Lawson claims elicitation of false testimony violated due process. | State contends any error was non-prejudicial; some impeachment evidence remained. | No reversible error; any misconduct did not materially prejudice the defendant. |
Key Cases Cited
- Brady v. Maryland, 373 U.S. 83 (1963) (favors suppression of exculpatory evidence violates due process)
- Bagley v. United States, 473 U.S. 667 (1985) (materiality of withheld evidence assessed cumulatively)
- Giglio v. United States, 405 U.S. 150 (1972) (prosecution must correct false testimony or risk due process violation)
- Napue v. Illinois, 360 U.S. 264 (1959) (false testimony violates due process when knowingly presented)
- Cone v. Bell, 129 S. Ct. 1769 (2009) (Brady/insanity defense context; contingent on collective impact on verdict)
- Chauncey v. State, 2006 WY 18 (Wy. 2006) (Brady analysis with cumulative evidence consideration in Wyoming)
- Davis v. State, 2002 WY 88, 47 P.3d 981 (Wy. 2002) (Brady analysis; discovery and impeachment evidence standards)
- Smith v. Secretary of New Mexico Dep’t of Corrections, 50 F.3d 801 (10th Cir. 1995) (cumulative undisclosed evidence may undermine confidence in outcome)