347 S.W.3d 73
Mo.2011Background
- Griffin filed a habeas petition challenging his murder conviction as violative of Brady v. Maryland due to undisclosed evidence that inmate Jeffrey Smith possessed a sharpened screwdriver.
- The State never disclosed Smith’s possession of the screwdriver, which Pratt alleged showed an alternate perpetrator.
- In trial, Curtis and Mozee testified Griffin stabbed the victim; Curtis testified under deal with incentives; Mozee impeachment via other witnesses.
- A screwdriver-like weapon found near the gym and blood testing were presented; no physical link tied Griffin to the weapon.
- Griffin’s penalty phase was remanded and he was resentenced to life imprisonment; the habeas petition was denied by the circuit court, leading to this Court’s review.
- The Court concludes the Brady evidence, viewed in totality, warrants relief by vacating Griffin’s conviction and discharging him unless the State elects to retry him.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether nondisclosure of Smith’s possession of the screwdriver violated Brady. | Griffin | Denney | Yes; disclosure was required and prejudicial. |
| Whether the screwdriver evidence is favorable to Griffin. | Griffin | Denney | Yes; it is exculpatory/impeaching and supports an alternative-perpetrator theory. |
| Whether the State suppressed the evidence. | Griffin | Denney | Yes; the state had a duty to disclose as investigators were part of the prosecution. |
| Whether Griffin was prejudiced by the nondisclosure. | Griffin | Denney | Yes; post-trial developments undermine confidence in the conviction. |
Key Cases Cited
- Brady v. Maryland, 373 U.S. 83 (U.S. 1963) (required disclosure of favorable evidence when material to guilt or punishment)
- Engel v. Dormire, 304 S.W.3d 120 (Mo. banc 2010) (habeas review limited to facial validity; cause and prejudice standard)
- Kyles v. Whitley, 514 U.S. 419 (U.S. 1995) (consideration of cumulative undisclosed evidence)
- Strickler v. Greene, 527 U.S. 263 (U.S. 1999) (external factors constituting cause for default; prejudice analysis)
- Berger v. United States, 295 U.S. 78 (U.S. 1935) (prosecutor’s duty to ensure justice, not merely win)
- State v. Bowman, 337 S.W.3d 679 (Mo. banc 2011) (necessity of a direct connection for alternate-perpetrator evidence)
- Storey v. State, 175 S.W.3d 116 (Mo. banc 2005) (definition of favorable evidence for Brady)
- Mo. v. Wood/Bartholomew, 516 U.S. 1 (U.S. 1995) (admissibility limits on evidence used to prove suppression)