413 So.3d 403
La.2025Background
- Darrell J. Robinson was convicted of first-degree murder and sentenced to death in Rapides Parish, Louisiana.
- Post-conviction proceedings established numerous instances where the prosecution failed to disclose exculpatory evidence (Brady violations), as documented in a nine-page Joint Stipulation of Facts.
- The prosecution also failed to correct a jailhouse informant’s false testimony about receiving favorable treatment (Napue/Giglio violation), where the informant was the only direct witness tying Robinson to the crime.
- The Louisiana Supreme Court reheard the case in light of the U.S. Supreme Court’s recent Glossip v. Oklahoma decision.
- Despite extensive dissenting opinions emphasizing due process and cumulative prejudice from the suppression, the majority reaffirmed Robinson’s conviction and death sentence.
Issues
| Issue | Robinson's Argument | State's Argument | Held |
|---|---|---|---|
| Brady Violations (Suppressed Evidence) | Cumulative suppressed evidence undermines verdict | Impact of each item not enough to warrant new trial | No new trial required |
| Napue/Giglio Violation (False Testimony) | Undisclosed deal with informant critical to case outcome | Testimony immaterial; case strong absent informant | No new trial required |
| Materiality Standard (Cumulative vs. Isolated) | Cumulative impact of evidence must be considered | Evidence not material in isolation or cumulatively | Majority: not material |
| Application of Glossip v. Oklahoma | Glossip supports vacating conviction due to fair trial | Glossip does not alter prior Louisiana decision | Glossip does not change outcome |
Key Cases Cited
- Brady v. Maryland, 373 U.S. 83 (Suppression of material exculpatory evidence by prosecution violates due process)
- Napue v. Illinois, 360 U.S. 264 (Use of false testimony by prosecution undermines due process)
- Giglio v. United States, 405 U.S. 150 (Government's duty to correct false testimony relating to witness credibility)
- Kyles v. Whitley, 514 U.S. 419 (Materiality of suppressed evidence analyzed cumulatively, not item-by-item)