United States v. Singletary
685 F. App'x 33
| 2d Cir. | 2017Background
- On Oct. 6, 2012, Rochester PD officer Amy Pfeffer and probation officer Robert Masucci stopped Laverne Singletary; after he fled, officers recovered multiple bags of marijuana and a handgun discarded on the sidewalk.
- Masucci processed the evidence at the station but filled out evidence labels attributing collection to Pfeffer (he later testified he did so as a convenience because his name was not in the RPD system).
- Pfeffer resigned before trial and would have invoked the Fifth Amendment, so Masucci was the key government witness.
- At trial, Masucci testified he completed the evidence labels; defense counsel cross-examined him aggressively, called an RPD witness who called the conduct “forgery,” and highlighted the labels in closing, but did not request a continuance.
- Singletary was convicted of being a felon in possession of a firearm and possession of marijuana, then moved for a new trial under Brady, arguing the government’s delayed disclosure of Masucci’s mislabeling prevented effective use of impeachment material.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether government violated Brady by disclosing impeachment material only at trial | Singletary: late disclosure of Masucci’s misstatements about evidence labels prevented effective impeachment and prejudiced the defense | Gov: disclosure occurred in time for effective use at trial; defense had opportunity to impeach and present evidence | No Brady violation; disclosure at trial was timely because defense effectively used the information and suffered no prejudice |
| Whether the mislabeling constituted prosecutorial misconduct warranting a new trial | Singletary: misconduct claim based on alleged concealment/mislabeling | Gov: no suppression of material evidence; defense confronted and used the evidence at trial | Court rejects misconduct claim for same reason — no prejudice |
Key Cases Cited
- Brady v. Maryland, 373 U.S. 83 (1963) (government must disclose favorable material evidence)
- Giglio v. United States, 405 U.S. 150 (1972) (Brady includes impeachment evidence)
- United States v. Coppa, 267 F.3d 132 (2d Cir. 2001) (Brady: disclosure must be in time for effective use)
- Leka v. Portuondo, 257 F.3d 89 (2d Cir. 2001) (Brady material may be disclosed during trial and still be timely)