Lawson v. State, 242 P.3d 993

Lawson was convicted of possession with intent to deliver cocaine and meth, plus possession of each drug, after a 2008 search of a residence.
Detective Edwards connected Lawson to the residence’s drug activity; informants implicated Torres, Bolton, Varela, and others with Torres as leader.
Recovered drugs and paraphernalia were found under a bed and in a pink backpack during the April 1, 2008 search.
Defense argued the State possessed exculpatory/ impeachment evidence not disclosed pretrial, and that the prosecutor solicited false testimony from a key witness (Giatroudakis).
Lawson moved for a new trial asserting Brady/Giglio violations; district court denied; Lawson pursued appeals and supplemental discovery.
On appeal, the Wyoming Supreme Court affirmed, concluding no material Brady violation and no reversible prosecutorial misconduct occurred, though admonished prosecutors.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Brady suppression materiality	Lawson contends the State suppressed exculpatory evidence.	Lawson argues undisclosed documents were material and undermined confidence in verdict.	No material Brady violation; cumulative evidence insufficient to undermine verdict.
Prosecutorial misconduct by eliciting false testimony	Lawson asserts the prosecutor solicited false testimony about a deal with Giatroudakis.	Lawson contends the testimony was false and prejudicial.	No reversible plain error; insufficient prejudice shown; district court did not abuse.

Brady v. Maryland, 373 U.S. 83 (U.S. 1963) (due process requires disclosure of favorable evidence)
Bagley v. United States, 473 U.S. 667 (U.S. 1985) (materiality and suppression considerations for impeachment evidence)
Giglio v. United States, 405 U.S. 150 (U.S. 1972) (impeachment evidence and prosecutorial withholding/misconduct concerns)
Napue v. Illinois, 360 U.S. 264 (U.S. 1959) (due process requires correction of false testimony)
Davis v. State, 2002 WY 88 (Wyoming 2002) (Wyoming Brady considerations and evidence evaluation)
Chauncey v. State, 2006 WY 18 (Wyoming 2006) (Brady-type analysis; cumulative evidence relevance)
State v. Smith, 50 F.3d 801 (10th Cir. 1995) (cumulative undisclosed evidence may undermine confidence in verdict)
Thomas v. State, 131 P.3d 348 (Wyoming 2006) (standard for materiality under Brady in Wyoming)
Cone v. Bell, 129 S. Ct. 1769 (U.S. 2009) (collective assessment of suppressed evidence on insanity defense)