United States v. Armando Mota
2012 U.S. App. LEXIS 13755
| 7th Cir. | 2012Background
- Mota was convicted of attempting to distribute 500+ grams of cocaine and possessing with intent to distribute 500+ grams, under 21 U.S.C. § 841(a)(1) and § 846.
- At trial, prosecutors learned that Agent Aponte failed to record and relay exculpatory talk by co-defendant Ponce claiming Mota’s innocence and naming “Teflon” as the real source.
- Mota’s counsel learned of this exculpatory interview at trial and cross-examined Aponte; Ponce testified for the defense.
- The government had audio of the drug-deal conversation; Ponce’s cell records showed post-talk contacts; Ponce admitted guilt but claimed Mota’s non-involvement.
- The jury convicted Mota; he appeals arguing Brady violation and insufficiency of evidence; the district court judgment is affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Brady violation from undisclosed interview | Mota asserts Brady violation due to undisclosed interview with Ponce | US argues no prejudice from late disclosure | No Brady violation; trial fair despite failure to disclose |
| Sufficiency of evidence | Evidence insufficient for guilt beyond a reasonable doubt | Evidence sufficiently supports conviction | Sufficient evidence supports guilt beyond a reasonable doubt |
Key Cases Cited
- Brady v. Maryland, 373 U.S. 83 (U.S. Supreme Court 1963) (duty to disclose exculpatory material)
- Banks, 546 F.3d 507 (7th Cir. 2008) (plain-error standard for Brady material)
- Bagley, 473 U.S. 667 (U.S. Supreme Court 1985) (materiality standard for Brady: reasonable probability of different result)
- Crivens v. Roth, 172 F.3d 991 (7th Cir. 1999) (prosecutors’ duty to learn favorable evidence)
- Kyles v. Whitley, 514 U.S. 419 (U.S. Supreme Court 1995) (duty to learn favorable evidence extends beyond their own knowledge)
- United States v. Daniel, 576 F.3d 772 (7th Cir. 2009) (plain-error review for Brady claims)
- United States v. Gray, 648 F.3d 562 (7th Cir. 2011) (mid-trial disclosure can suffice if time remains to use exculpatory material)
- United States v. Higgins, 75 F.3d 332 (7th Cir. 1996) (time to use exculpatory material governs continuance suitability)
- United States v. Grintjes, 237 F.3d 876 (7th Cir. 2001) (continuance as remedy for late disclosure)