United States v. Nelson, 979 F. Supp. 2d 123

Nelson pled guilty to traveling in interstate commerce to engage in illicit sexual conduct (18 U.S.C. § 2423(b)).
Nelson claims his plea was not knowing or voluntary because the government suppressed exculpatory evidence (the 1:44 p.m. email).
Detective Palchak, undercover, communicated with Nelson online; the 1:44 p.m. email suggested Nelson might be seeking methamphetamine, not sex with a minor.
Discovery packets provided to defense allegedly contained all electronic communications; later, the 1:44 p.m. email was found not to have been disclosed.
Nelson argues Brady v. Maryland required disclosure of exculpatory evidence and that non-disclosure prejudiced his decision to plead guilty; the court grants relief, vacates the conviction, and allows withdrawal of the guilty plea.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether a Brady violation can justify withdrawing a guilty plea.	Nelson argues Brady materiality undermines voluntariness of plea.	The government contends Ruiz limits plea-stage Brady rights.	Yes; Brady can support withdrawal of a guilty plea in this context.
Whether the 1:44 p.m. email was exculpatory material.	The email provides alternative explanations for motive and intent.	The government contends the email is ambiguously interpreted.	The email was exculpatory material for Brady purposes.
Whether the email was suppressed by the prosecution or investigators.	The government failed to disclose the email; defense relied on disclosures.	Nelson had knowledge or access and thus Brady did not apply.	Yes, the email was suppressed under Brady.
Whether suppression caused prejudice to Nelson at the plea stage.	But-for disclosure, Nelson would have gone to trial rather than plead.	Prejudice would be minimal because evidence existed elsewhere; defense could raise other theories.	Prejudice found; plea invalid.
Whether the defendant's knowledge of the evidence affects Brady duty.	Even if Nelson knew the general facts, he did not know the specific email was undisclosed.	If the defendant knows sufficient facts, Brady may be limited.	Brady duty applies regardless of defendant’s knowledge; government disclosure obligation remains.

Ruiz v. United States, 536 U.S. 622 (Supreme Court, 2002) (impeachment vs. exculpatory information at plea stage; not required for impeachment, but innocence evidence may be compelled)
Strickler v. Greene, 527 U.S. 263 (Supreme Court, 1999) (three Brady components; suppression and prejudice must be shown)
Banks v. Dretke, 540 U.S. 668 (Supreme Court, 2004) (reliance on prosecution's disclosure representations; duty to disclose not excused by defense investigation)
Sanchez v. United States, 50 F.3d 1448 (9th Cir., 1995) (Brady material at plea stage may undermine voluntariness of plea)
Derr v. United States, 990 F.2d 1330 (D.C. Cir., 1993) (Brady requires disclosure of unknown exculpatory information; defendant independent knowledge not dispositive)