People v. Chenault
495 Mich. 142
| Mich. | 2014Background
- Chenault was convicted of felony murder and felony-firearm after a shooting involving Harris; identity of shooter was the sole contested issue.
- Holloway’s videotaped interviews identifying Chenault were not provided to defense; written statements did not mention Chambers’s presence.
- Defense theory: Chambers committed the shooting and Holloway identified Chenault out of fear, with Chambers as the real shooter.
- Trial record showed no physical evidence tying Chenault or Chambers to the shooting; only Holloway and Chambers implicated Chenault and vice versa.
- After trial, defense moved for a new trial asserting Brady violations due to suppressed recordings; trial court granted relief.
- Court of Appeals reversed, applying the four-factor Lester test (including a diligence requirement); Michigan Supreme Court granted reviewed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether a diligence requirement is valid in Brady analysis | Chenault argues Lester is valid; diligence is required. | Prosecution argues Lester aligns with Brady; diligence helps fairness. | Diligence requirement overruled; Lester rejected |
| Proper Brady test to apply | Lester augments Brady beyond Strickler; more favorable to Chenault. | Brady requires suppression, favorability, materiality; Lester unnecessary. | Strickler three-factor test adopted as controlling |
| Whether suppressed recordings were material | Suppressed recordings could impeach key witnesses and undermine identification. | Even with suppression, the evidence was not material to guilt. | Suppressed evidence not material; Brady claim fails |
| Whether suppression warrants ineffective assistance finding | Failure to obtain recordings could prejudice defense strategy. | Materiality analysis same for Brady and Strickland prejudice; no prejudice shown. | No prejudice; ineffective assistance claim fails |
Key Cases Cited
- Brady v. Maryland, 373 U.S. 83 (U.S. 1963) (prosecution's suppression of favorable evidence violates due process when material)
- Strickler v. Greene, 527 U.S. 263 (U.S. 1999) (three-factor materiality test; suppression, favorability, materiality)
- Bagley v. United States, 473 U.S. 667 (U.S. 1985) (defines materiality; reasonable probability undermines confidence in outcome)
- Kyles v. Whitley, 514 U.S. 419 (U.S. 1995) (collective evaluation of suppressed evidence; government duty to know favorable evidence)
- Agurs v. United States, 427 U.S. 97 (U.S. 1976) (contexts for Brady applicability; unknown to defense concept)
- United States v. Meros, 866 F.2d 1304 (11th Cir. 1989) (fourth-factor Brady lineage cited by Lester)
- Valera v. United States, 845 F.2d 923 (11th Cir. 1988) (cited for diligence discussion in Brady context)
- Ruggiero, 472 F.2d 599 (2d Cir. 1973) (diligence-related Brady discussion cited in context)
- Cravero, 545 F.2d 406 (5th Cir. 1976) (early cautionary authority on Brady diligence cited)
- Lester v. People, 232 Mich. App. 262 (Mich. Ct. App. 1998) (four-factor Brady test including diligence later overruled)