Santana v. Lee
682 F. App'x 38
| 2d Cir. | 2017Background
- Petitioner Albert Santana, Jr. appealed denial of a 28 U.S.C. § 2254 habeas petition challenging his state murder conviction; district court adopted magistrate recommendation denying relief.
- Santana argued prosecutors suppressed Brady impeachment material: records of eyewitness Anthony Edwards’s New York arrest and guilty plea to felony theft.
- At trial Edwards identified Santana as the shooter on cross-examination; defense had impeached Edwards with prior Florida convictions but did not address the New York matter at trial.
- The state court had ordered the district attorney to provide conviction records for witnesses; the DA file contained an Edwards conviction sheet referencing Florida convictions and pending New York matters.
- The county court found the prosecution had disclosed the relevant material; the habeas court accepted that factual finding and concluded any nondisclosure was not materially prejudicial.
Issues
| Issue | Santana's Argument | Lee's Argument | Held |
|---|---|---|---|
| Whether prosecution suppressed Brady impeachment material about Edwards’s NY arrest/guilty plea | Prosecutors failed to disclose Edwards’s NY arrest/plea, which was favorable impeachment evidence | State provided conviction records per court order; DA file referenced Edwards’s NY matters | Court held state-court finding that Brady material was disclosed was not clearly erroneous; Santana failed to rebut presumption of correctness |
| If nondisclosure occurred, whether it was material (prejudicial) | Suppressed NY record would have meaningfully undermined Edwards’s credibility and created reasonable probability of different outcome | Even if undisclosed, impeachment would not produce reasonable probability of different verdict given corroborating evidence and felony-murder theory | Court held any nondisclosure was not material; no reasonable probability of different result |
Key Cases Cited
- Lewis v. Conn. Comm’r of Corr., 790 F.3d 109 (2d Cir. 2015) (standards for § 2254 factual findings and Brady review)
- Brady v. Maryland, 373 U.S. 83 (1963) (prosecutorial duty to disclose evidence favorable to accused)
- United States v. Estrada, 430 F.3d 606 (2d Cir. 2005) (theft convictions can be used to impeach witness credibility)
- Leka v. Portuondo, 257 F.3d 89 (2d Cir. 2001) (materiality standard for suppressed evidence on habeas review)
- Kyles v. Whitley, 514 U.S. 419 (1995) (definition of materiality: reasonable probability verdict would differ)
- United States v. Jackson, 345 F.3d 59 (2d Cir. 2003) (suppressed impeachment evidence may not require new trial when witness credibility already impeached)