People v. Garrett, 18 N.E.3d 722

Garrett was convicted of two counts of second-degree murder for killing a 13-year-old girl.
Defendant challenged whether the People violated Brady by not disclosing a federal civil action against Detective O’Leary alleging misconduct in an unrelated arson case.
The civil action against O’Leary was filed in EDNY in 1998, answered in 1998, and unsealed in 2001, after Garrett’s trial.
The defense argued the civil action could impeach O’Leary’s credibility and thus was Brady material.
The trial court, Appellate Division, and majority below concluded the People did not suppress information or that it was not material; the Court of Appeals reversed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Does the civil action against O’Leary constitute Brady impeachment material?	Garrett: evidence is favorable as impeachment of a key witness.	O’Leary’s misconduct allegations could exonerate or impeach him.	Yes, impeachment material.
Did the People suppress the information about the civil action?	Yes, they knew or should have known and failed to disclose.	No actual/constructive knowledge by the People; no Brady suppression.	No suppression.
Was the nondisclosed information material under Brady?	Material because it could affect credibility and outcome.	Lack of materiality; impeachment value minimal and unlikely to change result.	Not material.
Is O’Leary’s knowledge imputable to the People for Brady purposes under imputation doctrine?	Knowledge should be imputed given joint prosecution and police involvement.	Imputation limited when misconduct is collateral to case; not imputed if officer’s acts are unrelated.	No constructively imputable knowledge; not imputed.

Brady v. Maryland, 373 U.S. 83 (U.S. 1963) (duty to disclose favorable evidence in a criminal trial)
United States v. Bagley, 473 U.S. 667 (U.S. 1985) (materiality and due process in Brady context)
Strickler v. Greene, 527 U.S. 263 (U.S. 1999) ( Brady duty to disclose; materiality considerations)
Kyles v. Whitley, 514 U.S. 419 (U.S. 1995) (duty to learn favorable evidence known to others; imputation of police knowledge)
People v. Fuentes, 12 N.Y.3d 259 (N.Y. 2009) (New York materiality standard; reasonable possibility that disclosure would change outcome)
People v. Wright, 86 N.Y.2d 591 (N.Y. 1995) (imputation of informant/police knowledge to prosecutors; materiality analysis)
People v. Vasquez, 214 A.D.2d 93 (N.Y.1st Dept. 1995) (imputation limits for collateral police misconduct to Brady analysis)
People v. LaFontaine, 92 N.Y.2d 470 (N.Y. 1998) (LaFontaine rule on appellate review of first-instance decisions; materiality context later clarified)
People v. Concepcion, 17 N.Y.3d 192 (N.Y. 2011) (LaFontaine/Concepcion framework for reviewing Brady/constitutional questions)