State ex rel. Woodworth v. Denney
2013 Mo. LEXIS 4
| Mo. | 2013Background
- Mark Woodworth was convicted of murder, assault, burglary and armed criminal action for the Robertson killings and later sought habeas relief based on Brady violations.
- A special master found Brady violations (Lewis letters, Rochelle ex parte order violations) and prejudicial impact.
- Court deferred to the master’s credibility findings and adopted them, vacating Woodworth’s convictions and ordering release pending retrial.
- Brady analysis requires favorable evidence, suppression, and prejudice; prejudice assessed via a reasonable probability of a different result.
- The Lewis letters and ex parte order violations were not disclosed and were material and prejudicial, with added supporting evidence.
- Additional newly discovered evidence and investigation misconduct further supported the verdict not being worthy of confidence.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the Lewis letters were suppressed and prejudicial under Brady. | Woodworth that letters were favorability and undisclosed. | State contends letters either disclosed or not material. | Brady violation found; prejudice established; letters suppressed and prejudicial. |
| Whether Rochelle Robertson’s ex parte order violations were suppressed and prejudicial under Brady. | Woodworth shows reports were undisclosed and favorable to defense. | State argues reports were not properly in file or disclosed. | Brady violation found; prejudice established; nondisclosure undermined defense. |
| Whether additional newly discovered evidence corroborates prejudice or undermines confidence in verdict. | Woodworth argues totality supports not worthy of confidence. | State argues evidence is not dispositive. | Totality supports petition; master’s findings not against weight of evidence. |
Key Cases Cited
- Strickler v. Greene, 527 U.S. 263 (U.S. 1999) (Brady material prejudice standard expanded (favorable evidence; suppression; prejudice))
- Kyles v. Whitley, 514 U.S. 419 (U.S. 1995) (Materiality and reasonable probability of different result standard)
- Engel v. Dormire, 304 S.W.3d 120 (Mo. banc 2010) (Brady duty to learn of favorable evidence; state actors' duty)
- Lyons v. Lombardi, 303 S.W.3d 523 (Mo. banc 2010) (Master’s findings given weight in habeas review; substantial evidence standard)
- Murray v. Carrier, 477 U.S. 478 (U.S. 1986) (Cause and prejudice to excuse procedural default)