State of Iowa v. Brett Roelandt
16-1926
| Iowa Ct. App. | Aug 2, 2017Background
- Brett Roelandt pleaded guilty to first-degree theft and assault while participating in a felony as part of a plea agreement; robbery and felon-in-possession counts were dismissed.
- After plea acceptance, Roelandt filed a motion in arrest of judgment alleging the prosecutor failed to disclose an exculpatory statement from the victim made to the county attorney the morning of the plea.
- The alleged statement: the victim said he could not say Roelandt was the perpetrator and was unsure; it did not positively exclude Roelandt and partly mirrored earlier statements.
- Police evidence included the victim’s initial on-scene identification of Roelandt, testimony that Roelandt was wearing white (matching the victim’s description), and the victim’s girlfriend’s identification of Roelandt.
- The district court denied the motion in arrest of judgment; Roelandt appealed claiming a Brady violation for nondisclosure of exculpatory evidence.
- The court reviewed constitutional claims de novo and affirmed, holding any suppressed statement was not material because there was no reasonable probability of a different outcome.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether prosecutor’s nondisclosure of the victim’s statement violated Brady | State: Statement not Brady material and nondisclosure did not undermine confidence in outcome | Roelandt: Victim’s statement was exculpatory Brady material; nondisclosure violated due process and warrants setting aside plea | Court: Even if suppressed and favorable, statement was not material—no reasonable probability of different outcome; denial affirmed |
| Whether a guilty plea vitiates right to pre-plea Brady disclosure | State (concurring view): Following Ruiz, Brady-type impeachment not required pre-plea | Roelandt: Claimed entitlement to exculpatory evidence before plea | Court (concurring): Guilty plea waives right to certain pre-trial disclosures; Ruiz supports no requirement to disclose impeachment before plea |
Key Cases Cited
- Brady v. Maryland, 373 U.S. 83 (1963) (prosecution must disclose materially exculpatory evidence)
- United States v. Ruiz, 536 U.S. 622 (2002) (the government need not disclose impeachment information prior to a guilty plea)
- United States v. Bagley, 473 U.S. 667 (1985) (favorable evidence is material if disclosure creates reasonable probability of a different result)
- DeSimone v. State, 803 N.W.2d 97 (Iowa 2011) (defines "reasonable probability" standard for materiality under Brady)