State v. Dick
280 P.3d 445
Utah Ct. App.2012Background
- Dick was convicted in the Utah Court of Appeals for illegal possession of controlled substances and related offenses.
- Dick moved for a new trial alleging the State withheld evidence about a rebuttal witness and its tapes, violating Brady v. Maryland and Rule 16 Utah Rules of Criminal Procedure.
- The trial court denied the motion; on appeal Dick argues the State suppressed favorable or impeaching information and failed to disclose the rebuttal witness prior to trial.
- The court revisits the Brady framework under Doyle and addresses whether the State’s pretrial disclosure obligation and any suppression prejudiced Dick.
- The court considers whether defense knew of the possible inducement before trial and whether failure to pursue it at trial prejudiced Dick.
- Even if errors occurred, the court ultimately affirms the convictions, finding the evidence against Dick overwhelming and not plausibly reversible by the challenged disclosures.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Brady was violated by nondisclosure of a rebuttal witness | Dick asserts the State suppressed favorable information and interviews. | Dick contends Rule 16 and Brady require pretrial disclosure of the witness and potential inducements. | No reversible Brady violation; no prejudice shown. |
| Whether Rule 16 compliance was waived or violated | Dick claims the State violated Rule 16 by delaying disclosure. | Dick failed to seek relief or a continuance; waiver occurred. | Waived under Rule 16; no reversal. |
| Whether any disclosure error affected trial outcome | Nondisclosure could have altered cross-examination or outcome. | Defense could not prove material impact. | Even if error occurred, outcome unlikely to change; evidence overwhelming. |
Key Cases Cited
- State v. Bisner, 37 P.3d 1073 (Utah 2001) ( Brady analysis; due process standard and prejudice required for reversal)
- United States v. Bagley, 473 U.S. 667 (U.S. 1985) (material and exculpatory evidence; reasonable probability of different outcome)
- State v. Doyle, 245 P.3d 206 (Utah Ct. App. 2010) (discovery duties; waiver when defense does not pursue relief)
- State v. Griffiths, 752 P.2d 879 (Utah 1988) (evaluation of discovery violations and prejudice considerations)
- State v. Knight, 734 P.2d 913 (Utah 1987) (prejudice standard for discovery violations in Utah)
- Strickler v. Greene, 527 U.S. 263 (U.S. 1999) (three-part Brady test: favorable, suppressed, prejudicial)