State v. Brown, 184 So. 3d 1265

David Brown, one of five inmates involved in an Angola prison escape attempt, was convicted of first-degree murder of Captain David Knapps and sentenced to death.
After sentencing, Brown learned the State had interviewed inmate Richard Domingue, who reported that co-defendant Barry Edge told him that Edge and Jeff Clark decided to kill Captain Knapps and that others (including Brown) were not part of that decision.
Brown moved for a new penalty-phase trial, arguing Domingue’s statement was Brady material the State should have disclosed because it supported mitigation (reduced moral culpability).
The district court granted a new penalty-phase trial in part, finding potential undermining of confidence in the sentence.
The appellate court reversed, and the Supreme Court (per curiam) denied the writ, holding the undisclosed statement was neither favorable nor material under Brady and that the district court abused its discretion in ordering a new penalty-phase trial.

Issue	Brown's Argument	State's Argument	Held
Whether failure to disclose Domingue’s statement violated Brady	Domingue’s statement is favorable/impeaching and mitigates Brown’s moral culpability because it shows Edge and Clark decided to kill Knapps	Statement is not favorable to Brown, does not exculpate him, and was not material to penalty outcome	No Brady violation; nondisclosure not material; writ denied
Whether nondisclosure undermined confidence in the penalty verdict (materiality/prejudice)	The statement could have persuaded jury to impose life instead of death by showing Brown was not part of the decision to kill	Statement provides no direct evidence who killed Knapps and would not have likely changed jury’s sentencing decision	Not material under Brady; district court abused discretion in granting new penalty-phase trial

Strickler v. Greene, 527 U.S. 263 (U.S. 1999) (sets three Brady components: favorable, suppressed, and prejudicial/material)
Kyles v. Whitley, 514 U.S. 419 (U.S. 1995) (materiality standard: whether suppression undermines confidence in outcome)
United States v. Bagley, 473 U.S. 667 (U.S. 1985) (materiality/standard cited in Kyles)
State v. Bright, 875 So.2d 37 (La. 2004) (discusses limited scope of Brady and materiality in state context)
Lockett v. Ohio, 438 U.S. 586 (U.S. 1978) (capital sentencer must consider any mitigating evidence defendant proffers)
Banks v. Dretke, 540 U.S. 668 (U.S. 2004) (Brady materiality applied in capital sentencing context)