United States v. Brumfield, 89 F.4th 506

In December 2013, a Loomis armored truck robbery in New Orleans resulted in the fatal shooting of a guard and the theft of $260,000.
Six people were indicted; Robert Brumfield III and Jeremy Esteves were convicted at trial on conspiracy and robbery-related charges.
Key government witness Jamell Hurst, an FBI informant, testified against both men and his testimony was central to implicating them.
During and after trial, previously undisclosed evidence surfaced suggesting Hurst received additional promises or benefits from the government for his cooperation.
Brumfield and Esteves moved for a new trial based on alleged Brady/Giglio violations (suppression of exculpatory or impeachment evidence), which the district court denied.
They appealed the denial; Brumfield also appealed his sentence and raised a Napue claim (government use of false testimony).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Brady/Giglio violation—suppression of impeachment evidence	Brumfield & Esteves: Government failed to disclose material benefits/promises to Hurst that would have undermined his credibility.	Govt: Either evidence was cumulative or not material, as Hurst’s credibility was already impeached, and other corroborating evidence existed.	Not material as to Brumfield, but material as to Esteves—Esteves’s claim remanded for further findings; no new trial for Brumfield.
Napue violation—presentation of false testimony	Brumfield: Govt knowingly allowed false testimony regarding benefits Hurst received for cooperating.	Govt: No knowing presentation of false testimony; any inconsistencies not material to the verdict.	No Napue violation; Brumfield failed to show materially false testimony knowingly presented.
Procedural reasonableness of Brumfield's sentence	Brumfield: Errors in factual findings, application of murder cross-reference, and denial of minor-participant reduction.	Govt: District court’s findings were plausible and grounded in the record.	No procedural or substantive error; district court affirmed.
Use of acquitted conduct to enhance sentence	Brumfield: Enhancement based on acquitted conduct is improper.	Govt: Supreme Court precedent allows consideration of acquitted conduct.	Use of acquitted conduct is permissible under existing precedent.

Brady v. Maryland, 373 U.S. 83 (suppression of material exculpatory evidence violates due process)
Giglio v. United States, 405 U.S. 150 (suppression of impeachment evidence violates due process)
Napue v. Illinois, 360 U.S. 264 (use of knowingly false testimony violates due process)
Smith v. Cain, 565 U.S. 73 (material impeachment evidence where sole eyewitness’s credibility was at issue)
Wearry v. Cain, 577 U.S. 385 (materiality of undisclosed motives of key witnesses)
United States v. Watts, 519 U.S. 148 (acquitted conduct may be considered at sentencing)