State v. Worley, 476 P.3d 1212

Nancy Mitchell’s decomposing body was found in Eddy County, NM in January 1982; Curtis Worley was tried, convicted of felony murder and first-degree criminal sexual penetration, and sentenced to life plus 18 years; convictions were affirmed on direct appeal.
Co-defendant Carl Case was tried separately; years later Case pursued state and federal habeas relief raising recanted eyewitness testimony, newly run DNA tests, and an allegedly suppressed February 3, 1982 statement by eyewitness Bobby Autry.
Worley filed a habeas petition (2004), later supplementing it with the Autry statement and DNA evidence developed in the Case proceedings; the district court granted Worley a writ and a new trial without issuing detailed findings, relying largely on transcripts from the Case evidentiary hearings.
The State appealed; the Supreme Court of New Mexico reviewed whether the Autry statement triggered a Brady violation and whether the proffered “new” evidence (recantations, DNA, Autry statement) established actual innocence or justified a new trial.
The Court held the Autry statement, while impeaching, was cumulative and not material under Brady, and that the recantations and DNA evidence did not constitute new, reliable evidence that would make it clear no reasonable juror would convict; it reversed the district court’s grant of habeas relief and new trial.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Worley)	Held
Whether suppression of Autry’s Feb. 3, 1982 statement violated Brady	No Brady violation; suppressed evidence was not material to verdict	Autry tape was favorable/impeaching and its nondisclosure was material and undermined trial fairness	Court: presumed suppression for analysis, found statement favorable but cumulative and not material — no Brady violation
Whether recanted eyewitness testimony, new DNA, and the Autry statement constitute "new evidence" supporting actual innocence / a new trial	The proffered evidence is cumulative, impeaching, or inconclusive and would not likely change the verdict	The recantations, new DNA testing, and suppressed statement are new and undermine confidence in the verdict, so habeas/new trial is warranted	Court: recantations were not qualitatively new, DNA showed absence (not exculpatory), Autry statement cumulative — evidence fails to meet new-evidence/actual-innocence standards; no new trial
Standard of review and district court’s failure to enter findings	Deferential review supports reversal because record does not sustain habeas grant	District court erred by not making findings; some urge de novo review for mixed legal questions	Court reviewed legal questions de novo, factual findings for supportability; reversed habeas grant for misapplication of law; concurrence stressed Rule 1-052 and urged courts to enter findings

Brady v. Maryland, 373 U.S. 83 (1963) (prosecution’s suppression of evidence favorable to accused violates due process)
Strickler v. Greene, 527 U.S. 263 (1999) (materiality and prejudice framework for Brady claims)
United States v. Bagley, 473 U.S. 667 (1985) (impeachment evidence is covered by Brady; adopts reasonable-probability materiality test)
Kyles v. Whitley, 514 U.S. 419 (1995) (prosecutor must learn of favorable evidence known to others acting for the government)
Giglio v. United States, 405 U.S. 150 (1972) (prosecutor responsible for nondisclosure whether negligent or intentional)
Smith v. Cain, 565 U.S. 73 (2012) (Brady involves legal determination reviewed de novo)
Cone v. Bell, 556 U.S. 449 (2009) (Brady violations implicate Fourteenth Amendment due process)
United States v. Agurs, 427 U.S. 97 (1976) (earlier Agurs formulations of materiality discussed and explained as superseded by Bagley)
State v. Case (Case II), 144 N.M. 20, 183 P.3d 905 (2008) (New Mexico’s analysis of the Autry statement, recantations, and materiality; heavily relied upon)
Montoya v. Ulibarri, 142 N.M. 89, 163 P.3d 476 (2007) (standard for freestanding actual-innocence claim on habeas)
State v. Rosales, 136 N.M. 25, 94 P.3d 768 (2004) (third-person motive evidence must have direct or circumstantial link to crime)
United States v. Cooper, 654 F.3d 1104 (10th Cir. 2011) (discusses evaluating suppressed impeachment evidence in context of entire record)