Rodrigues Talbert v. Bryan Morrison, 24-1338

Rodrigues Talbert was convicted in Michigan state court of first-degree felony murder for his role in a 2006 robbery and killing.
Key evidence at trial included DNA matching Talbert to fresh blood found at the crime scene and eyewitness identification by Nicole Vaid, the victim's girlfriend.
After trial, it was discovered that the prosecution failed to disclose Vaid’s prior 2006 testimony, which contained inconsistencies with her later trial testimony.
Talbert argued this non-disclosure was a Brady violation and sought habeas relief, claiming the missing evidence was material to his defense.
The Michigan Court of Appeals and the federal district court denied relief, both concluding the suppressed evidence was not material given the strength of other evidence.
The Sixth Circuit Court of Appeals affirmed denial of the habeas petition.

Issue	Talbert’s Argument	State’s Argument	Held
Whether non-disclosure of Vaid’s prior inconsistent testimony was a material Brady violation	The withheld testimony could have impeached the prosecution’s key witness, undermining the reliability of her identification and the verdict	The evidence was immaterial because Talbert's presence at the scene was supported by DNA and he was already heavily impeached at trial	The suppressed evidence was not material; no reasonable probability of a different verdict

Brady v. Maryland, 373 U.S. 83 (prosecution must disclose favorable evidence to the accused)
Strickler v. Greene, 527 U.S. 263 (standard for proving a Brady claim)
Kyles v. Whitley, 514 U.S. 419 (evidence is material if its suppression undermines confidence in the verdict)
United States v. Bagley, 473 U.S. 667 (defines materiality for Brady claims)