Smith v. Cain
132 S. Ct. 627
| SCOTUS | 2012Background
- Louisiana convicted Smith of five counts of first-degree murder based on Boatner’s eyewitness identification only; no other evidence linked Smith to the crime.
- Postconviction discovery revealed Ronquillo notes with Boatner statements contradicting trial testimony; nondisclosure raised Brady claim.
- Louisiana courts denied Brady relief; Supreme Court granted certiorari and reversed, holding nondisclosed notes were Brady material.
- Court held undisclosed Boatner statements were material to guilt; there was a reasonable probability of different outcome, given Boatner was the sole linking witness.
- Court declined to consider other undisclosed items after finding Boatner’s statements alone suffice to undermine confidence in conviction.
- Dissent argues cumulative, not singular, undisclosed evidence could be insufficient to warrant new trial; would affirm trial court.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether undisclosed notes by the lead detective about Boatner’s inability to ID a perpetrator are Brady material | Smith argues undisclosed notes were favorable and material | State contends notes are immaterial given other evidence | Yes, material; Brady violation found and conviction reversed |
| Whether undisclosed statements could undermine confidence in verdict given Boatner's identifications | Smith claims cumulative effect undermines verdict | State argues other evidence supports conviction | Yes, material; Boatner’s undisclosed statements alone undermine confidence |
| Whether other undisclosed items (Russell, Mims, Leary, Trackling/Rogers, Young) change result cumulatively | Smith relies on cumulative undisclosed items | State asserts cumulative effect not proven to change outcome | Not reached; majority relied on Boatner alone for reversal |
Key Cases Cited
- Brady v. Maryland, 373 U.S. 83 (U.S. 1963) (duty to disclose favorable evidence in criminal prosecutions)
- Cone v. Bell, 556 U.S. 449 (U.S. 2009) (materiality standard; reasonable probability of different outcome)
- Kyles v. Whitley, 514 U.S. 419 (U.S. 1995) (materiality requires probability of different result, not certainty)
- United States v. Agurs, 427 U.S. 97 (U.S. 1976) (impeachment and exculpatory evidence; materiality under Brady clarifications)
- Strickler v. Greene, 527 U.S. 263 (U.S. 1999) (burden to show reasonable probability of different verdict)
- United States v. Bagley, 473 U.S. 667 (U.S. 1985) (defining materiality in Brady context)