State v. Robinson
309 Kan. 159
| Kan. | 2019Background
- In 2008 Robinson was convicted by a Sedgwick County jury of capital murder and related offenses and sentenced to life without parole plus additional months; convictions were affirmed on direct appeal.
- Robinson filed a K.S.A. 60-1507 ineffective-assistance claim in 2012, which was denied and affirmed on appeal.
- In 2015 Robinson filed a pro se motion seeking postconviction discovery under K.S.A. 2015 Supp. 60-237 and Brady/Giglio, alleging Detective Timothy Relph had credibility problems and that the State withheld exculpatory/ impeachment material.
- The State responded that criminal discovery is governed by K.S.A. 2015 Supp. 22-3212, that it had no Brady/Giglio material regarding Relph, but acknowledged the State’s continuing Brady duty to disclose favorable evidence known at trial.
- The district court denied Robinson’s motion and his reconsideration request (which sought in camera review of Relph’s personnel file), concluding 60-237 does not authorize postconviction discovery in a criminal case and the State affirmatively stated no Brady material existed.
- Robinson appealed; the Kansas Supreme Court reviewed whether K.S.A. 2015 Supp. 60-237 permits postconviction discovery and affirmed the denial.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether K.S.A. 2015 Supp. 60-237 authorizes postconviction discovery in a criminal case | Robinson: 60-237 permits a postconviction motion to compel Brady/Giglio discovery | State: Criminal discovery is governed by K.S.A. 22-3212; 60-237 applies to pending civil actions, not postconviction criminal proceedings | Court: 60-237 does not permit postconviction discovery in a criminal case; affirm denial |
| Whether court should order in camera review of a witness’s personnel file for Brady/Giglio material | Robinson: Court should review Relph’s file to uncover undisclosed impeachment evidence | State: No Brady/Giglio material exists; no statutory basis for postconviction discovery | Court: No statutory authority for such postconviction compulsion; State’s assertion it had no Brady material was sufficient |
Key Cases Cited
- State v. Robinson, 293 Kan. 1002, 270 P.3d 1183 (2012) (affirming convictions challenged in earlier direct appeal)
- State v. Brosseit, 308 Kan. 743, 423 P.3d 1036 (2018) (statutory interpretation reviewed de novo)
- Brady v. Maryland, 373 U.S. 83 (1963) (prosecution must disclose materially exculpatory evidence)
- Giglio v. United States, 405 U.S. 150 (1972) (prosecution must disclose evidence affecting witness credibility)