State v. Huebler
128 Nev. 192
| Nev. | 2012Background
- Huebler timely sought post-conviction relief on an untimely petition after pleading guilty to lewdness with a child under 14.
- He alleged Brady withholding of exculpatory surveillance videotapes rendered his guilty plea involuntary, causing delay.
- District court found exculpatory, withheld, and material evidence, granting relief; State appealed.
- Nevada Supreme Court addressed whether Brady requires disclosure before a guilty plea and the proper materiality standard in that context.
- Court held that exculpatory material must be disclosed before a guilty plea and adopted a substantial-materiality test; it reversed on the Brady claim due to lack of materiality.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Brady requires pre-plea disclosure of exculpatory evidence | Huebler argues Brady requires disclosure before plea. | State contends no pre-plea disclosure obligation for exculpatory materials under Ruiz. | Yes; pre-plea disclosure required. |
| What is the appropriate materiality test for pre-plea Brady claims | Use Sanchez framework with specific-request modification. | Discretion to apply standard adequate under Ruiz and Nevada law. | Adopt Sanchez-based materiality test with distinction for specific requests; require showing a reasonable probability the defendant would have declined the plea. |
| Is the district court's application of materiality correct in this case | Surveillance tapes were exculpatory and material, affecting defense strategy. | Evidence was not material; pre-plea disclosure would not have changed the plea. | No; materiality not shown under the adopted test; district court's ruling reversed. |
| Relation between good cause for delay and Brady claims in NRS 34.726 petitions | Delay was caused by State withholding evidence; prejudice established. | No sufficient showing of external impediment or prejudice. | Good-cause requirement not satisfied; petition time-bar upheld. |
Key Cases Cited
- Brady v. Maryland, 373 U.S. 83 (1963) (duty to disclose favorable evidence)
- Sanchez v. United States, 50 F.3d 1448 (9th Cir. 1995) (materiality test for guilty-plea Brady claims; specific-request variation)
- United States v. Ruiz, 536 U.S. 622 (2002) (impeachment info before plea; limits on disclosure; distinction from exculpatory evidence)
- Hill v. Lockhart, 474 U.S. 52 (1985) (prejudice in ineffective assistance context; subjective to objective analysis)
- Mazzan v. Warden, 116 Nev. 48 (2000) ( Brady materiality standard; 'reasonable probability' framework in Nevada context)
- Hathaway v. State, 119 Nev. 248 (2003) (good cause; external impediment for delay)
- State v. Sturgeon, 231 Wis. 2d 487 (Wis. Ct. App. 1999) (Wisconsin factors for materiality in guilty-plea Brady claims)
- Roberts v. State, 110 Nev. 1121 (1994) (separate materiality tests based on whether there was a specific request)