Lewis v. Connecticut Commissioner of Correction
790 F.3d 109
| 2d Cir. | 2015Background
- In 1990 Scott Lewis was tried and convicted in Connecticut for two murders; the prosecution’s case relied almost entirely on testimony by Ovil Ruiz, who said he drove Lewis and Stefon Morant to the scene and later overheard admissions.
- Ruiz initially denied any knowledge of the murders during police questioning on Jan. 13–14, 1991, but later gave an inculpatory statement after Detective Vincent Raucci described case details and reportedly told Ruiz he would be released if he implicated others.
- Detective Michael Sweeney, Raucci’s supervisor, later testified (at a separate hearing) that Ruiz repeatedly denied involvement until Raucci coached him and promised to “let him go,” and that Ruiz told Sweeney he was parroting Raucci.
- The state habeas court denied Lewis’s Brady claim, finding exculpatory material was either furnished or available with due diligence; that decision omitted key aspects of Sweeney’s testimony.
- The federal district court held the state habeas ruling both contradicted Brady jurisprudence (no “due diligence” requirement) and rested on unreasonable factual findings, granted habeas relief, and ordered Lewis’s release unless retried; the Second Circuit affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Lewis procedurally defaulted Brady claim in state court | Lewis argued he complied with state procedural rules and raised Brady; Appellate Court’s dismissal didn’t clearly rest on a state procedural bar | State argued inadequate record and failure to brief certification issue barred federal review | No procedural bar — Lewis’s pro se filings and record were sufficient for federal review |
| Whether state habeas court applied improper legal standard (imposed "due diligence") | Lewis: state court erred by requiring defendant to have exercised due diligence to obtain Brady material | State: "due diligence" language was benign or relevant only to other claims | Held that imposing a due diligence requirement contradicted Brady and Supreme Court precedent |
| Whether the state court unreasonably determined facts regarding police coaching and non‑disclosure | Lewis: Sweeney’s credible testimony showed Raucci coached Ruiz and Ruiz recanted to Sweeney; this was not disclosed to defense | State: argued facts were insignificant or available to defense; prosecution did not possess or need to disclose all items | Held state court’s factual findings were unreasonable because it ignored key evidence and Sweeney’s credibility; suppression occurred |
| Whether suppressed evidence was material (prejudice) under Brady/Kyles | Lewis: Ruiz was the sole direct witness implicating him; undisclosed impeachment evidence would have undermined confidence in verdict | State: argued no reasonable probability of different result or that evidence was immaterial | Held suppressed impeachment evidence was material — undermined confidence in outcome; prejudice established |
Key Cases Cited
- Brady v. Maryland, 373 U.S. 83 (1963) (prosecution must disclose material exculpatory evidence)
- United States v. Bagley, 473 U.S. 667 (1985) (materiality standard for nondisclosure: reasonable probability of different result)
- Giglio v. United States, 405 U.S. 150 (1972) (Brady applies to impeachment evidence and promises to witnesses)
- Kyles v. Whitley, 514 U.S. 419 (1995) (prejudice/materiality inquiry: undermines confidence in verdict)
- Williams v. Taylor, 529 U.S. 362 (2000) (deference under AEDPA: clearly established federal law means Supreme Court holdings)
- Strickler v. Greene, 527 U.S. 263 (1999) (three-part Brady test: favorable, suppressed, prejudicial)
- United States v. Agurs, 427 U.S. 97 (1976) (Brady duty exists even without a defense request in some circumstances)
- Coleman v. Thompson, 501 U.S. 722 (1991) (procedural default doctrine barring federal habeas review)