Matthews v. Capra
699 F. App'x 98
| 2d Cir. | 2017Background
- Matthews was convicted in 2010 of selling $100 of crack cocaine to a confidential informant, Vicki Arquette, after a controlled buy; recordings of five call attempts and the buy were played at trial.
- Prosecution witnesses included Arquette and accomplice Jason Nassivera, both testifying Matthews was present and identified as the seller; Matthews testified and claimed mistaken identity.
- After conviction, Matthews contended the prosecution suppressed a police report showing a controlled buy in another case (involving Corey Martin) that used the same phone number Arquette dialed.
- The New York Appellate Division rejected Matthews’s Brady claim as not showing a reasonable probability of a different outcome; leave to appeal to the state high court was denied.
- The federal District Court granted Matthews’s §2254 habeas petition, finding the Appellate Division’s prejudice determination unreasonable; the State appealed.
- The Second Circuit vacated the district court’s grant and remanded, holding the Appellate Division reasonably applied Brady given the overwhelming trial evidence (eyewitness testimony and phone/buy recordings).
Issues
| Issue | Matthews' Argument | Capra's Argument | Held |
|---|---|---|---|
| Whether nondisclosure of a police report showing a different dealer answered the same phone number violated Brady (i.e., was the evidence material?) | The Report was exculpatory and, if disclosed, created a reasonable probability of a different result by supporting mistaken identity. | The Report was not material given eyewitness IDs, call recordings, and the buy recording; nondisclosure would not have changed the outcome. | Held for Capra: No Brady violation — Appellate Division reasonably concluded no reasonable probability of a different outcome. |
| Whether the District Court’s factual findings and legal conclusion that the state court unreasonably applied Brady were correct | District Court: state court unreasonably applied Brady; nondisclosure prejudiced Matthews. | State: District Court overlooked trial recordings and mischaracterized the record; state court’s decision was reasonable. | Held for Capra: District Court erred — it relied on incorrect factual findings; Second Circuit vacated the habeas grant and remanded. |
Key Cases Cited
- Brady v. Maryland, 373 U.S. 83 (1963) (suppression of evidence favorable to accused violates due process)
- Pennsylvania v. Ritchie, 480 U.S. 39 (1987) (materiality standard: reasonable probability of a different result)
- Carmichael v. Chappius, 848 F.3d 536 (2d Cir. 2017) (AEDPA unreasonable-application standard and limits on federal habeas relief)
- Overton v. Newton, 295 F.3d 270 (2d Cir. 2002) (standard of review for habeas corpus grants)
- People v. Matthews, 101 A.D.3d 1363 (N.Y. App. Div. 2012) (state appellate decision rejecting Brady prejudice claim)