Longus v. United States
52 A.3d 836
D.C.2012Background
- Longus was convicted of armed second-degree murder and possession of a firearm during a crime of violence for a drive-by shooting that killed Maurice Brown.
- Two main witnesses (Cooley-Hinton and Scott) testified for the government, describing a blue truck and varying roles of the driver and passenger in the shooting.
- The defense impeached Cooley-Hinton with Detective Brown’s prior statement and Brown’s later testimony; Brown’s testimony conflicted with his police report.
- Brown’s conduct in the Club U investigation suggested witness coaching; the defense attempted to cross-examine Brown about that corruption bias but the court restricted it.
- After trial, new information emerged about coaching in Club U, leading to a post-conviction § 23-110 motion arguing Napue/Brady violations and Sixth Amendment confrontation limits; the trial court denied.
- The court reverses and remands for a new trial based on the Sixth Amendment confrontation violation; Napue issue is discussed but not finally resolved.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Napue due process duty to correct false testimony | Longus argues government knew of false testimony and failed to correct | Longus contends government failure to correct false testimony violated due process | Napue applies; government must correct false or misleading testimony |
| Sixth Amendment confrontation right and cross-examination limits | Longus contends limitations prevented meaningful bias cross-examination | State argues limits were proper to prevent confusion | Confrontation right violated; limits prevented meaningful cross-examination; reversal and remand for new trial |
| Prejudice and harmlessness under Chapman | Impaired impeachment of Detective Brown affected verdict | State asserts harmlessness beyond reasonable doubt | Harmless error standard not met; prejudice found supporting reversal |
Key Cases Cited
- Napue v. Illinois, 360 U.S. 264 (U.S. 1959) (prosecution must correct false testimony or permit its correction to protect due process)
- Giglio v. United States, 405 U.S. 150 (U.S. 1972) (concerns impeachment evidence affecting credibility)
- Smith v. Phillips, 455 U.S. 209 (U.S. 1982) (due process fairness; cross-examination of bias and credibility)
- Delaware v. Van Arsdall, 475 U.S. 673 (U.S. 1986) (Sixth Amendment bias cross-examination; meaningful cross-examination)
- Davis v. Alaska, 415 U.S. 308 (U.S. 1974) (beyond physical confrontation, right to expose bias through cross-examination)