Stevens v. People, 2011 V.I. Supreme LEXIS 16

Stevens was convicted by a jury of multiple counts arising from Ward shootings; only Count IX, Unauthorized Possession of Ammunition, was reversed on appeal.
Stevens later filed a post-sentencing motion for a new trial alleging Brady violations based on newly discovered evidence from the Cockayne homicide investigation and Ward’s early prison release.
The asserted Brady material included police reports and an affidavit tied to Cockayne, which Stevens claimed could impeach Ward’s credibility.
Ward was the victim of a separate 2006 shooting; he testified at Stevens’ trial and Ward later faced his own trial for the Cockayne homicide in 2008.
The Superior Court denied Stevens’ Brady motion, finding no suppression, no materiality, and no probability that the outcome would differ; Stevens appealed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether undisclosed evidence was material under Brady	Stevens argues evidence was suppressed and material thus could change outcome.	Stevens contends the evidence lacked materiality and did not alter verdict.	No Brady violation; undisclosed evidence not material.
Whether Ward’s premature release created a quid pro quo	Stevens asserts an undisclosed agreement for Ward’s early release existed.	Stevens relies on Ward order but fails to prove an undisclosed agreement.	No proof of undisclosed quid pro quo; not material.
Whether Ward’s protective custody was suppressed or misrepresented	Stevens claims misrepresentation of Ward’s custody status violated Brady.	Prosecution promptly disclosed Ward’s protective custody status.	No suppression; disclosure was timely and not Brady-relevant.
Whether Cockayne homicide records were required to be disclosed	Documents from Cockayne investigation could impeach Ward and undermine verdict.	No duty to disclose investigative materials not connected to Stevens; not material.	No duty to disclose; materials not material to Stevens’ trial.

Brady v. Maryland, 373 U.S. 83 (U.S. 1963) (due-process requires disclosure of favorable evidence material to guilt or punishment)
Kyles v. Whitley, 514 U.S. 419 (U.S. 1995) (materiality assessed by whether evidence undermines confidence in verdict)
Giglio v. United States, 405 U.S. 150 (U.S. 1972) (disclosure burdens include impeachment evidence material to credibility)
United States v. Agurs, 427 U.S. 97 (U.S. 1976) (non-disclosure not automatic error; evaluate materiality context)
Bowry v. People, 52 V.I. 264 (V.I. 2009) (abuse-of-discretion standard for Brady-based new-trial motions)
Riley v. Taylor, 277 F.3d 261 (3d Cir. 2001) (definition of materiality and reasonable probability)
United States v. Perdomo, 929 F.2d 967 (3d Cir. 1991) (prosecution's knowledge scope extends to prosecution team)
United States v. Bagley, 473 U.S. 667 (U.S. 1985) (materiality requires reasonable probability of different outcome)