Murray v. United States
704 F.3d 23
1st Cir.2013Background
- Murray was convicted in 1984 of one count of conspiracy to possess marijuana, stemming from a 1983-84 multi-defendant conspiracy in Boston.
- Evidence included seizures from two vehicles and a warehouse, with a warrant affidavit partly based on warrantless observations and informants; the warehouse entry was warrantless but followed by a search warrant.
- Murray challenged the suppression of warehouse evidence; the district court denied suppression, holding the warrant supported by probable cause independent of the warrantless entry.
- Decades later, Murray filed a coram nobis petition (2007) claiming the FBI knew Bulger supplied the warehouse information and lied, which would have affected suppression and trial testimony.
- The district court assumed in Murray's favor that Bulger aided the FBI and that there was some misrepresentation, but found no fundamental error; Murray appealed the denial.
- The First Circuit affirmed, holding that even with assumed facts in Murray’s favor, the petition failed to show fundamental error or material Brady violations and thus coram nobis relief was unwarranted.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether coram nobis relief is available under the three-part test. | Murray argues eligibility satisfied by assumed falsity and ongoing collateral consequences. | Government contends Murray fails to show fundamental error despite assumptions. | Not satisfied; coram nobis denied |
| Whether the Bulger information was material to the warrant affidavit under Brady. | Bulger's identity would have undermined the warrant and credibility of agents. | Other CI information supported probable cause; Bulger info not material. | Not material; no Brady violation |
| Whether the withheld information would have changed the outcome at trial. | Assumed impeachment value of Bulger-related disclosures would affect trial. | Strong direct evidence of Murray's guilt remained independent of Bulger disclosures. | Not outcome-determinative; no fundamental error |
| Whether Murray’s post-remand agreement affects finality and coram nobis entitlement. | Agreement resembles a guilty plea that should not bar coram nobis. | Finality concerns apply; agreement weighed against relief. | Finality concerns do not warrant relief here; still denied |
Key Cases Cited
- United States v. George, 676 F.3d 249 (1st Cir. 2012) (three-part test and discretion in coram nobis relief)
- United States v. Mayer, 235 U.S. 55 (U.S. 1914) (fundamental errors of the kind coram nobis seeks to correct)
- United States v. Morgan, 346 U.S. 502 (U.S. 1954) (All Writs Act authority to issue coram nobis)
- Denedo v. United States, 556 U.S. 904 (U.S. 2009) (coram nobis restraint and availability considerations)
- Carlisle v. United States, 517 U.S. 416 (U.S. 1996) (restraint in issuing writs of coram nobis)
- United States v. Barrett, 178 F.3d 34 (1st Cir. 1999) (Jencks Act and government disclosure arguments within coram nobis context)
- Kyles v. Whitley, 514 U.S. 419 (U.S. 1995) (materiality standard for suppressed evidence)
- United States v. Bagley, 473 U.S. 667 (U.S. 1985) (materiality and impact of suppressed evidence on outcomes)