United States v. Stephanie Lorraine Prendergast
697 F. App'x 625
| 11th Cir. | 2017Background
- Defendant Stephanie Prendergast was convicted of making a false claim of U.S. citizenship (18 U.S.C. § 1015(e)) and using/attempting to use a false passport (18 U.S.C. § 1543).
- Post-verdict she moved for a new trial, arguing the government suppressed evidence of a fake passport from the Suresh Benny matter that had similar biographical data.
- Prendergast claimed disclosure of that passport would have shown two government witnesses (Williams and Vila) gave false testimony, triggering a Giglio-based new-trial claim.
- The district court denied the motion, applying Brady materiality principles; this appeal challenges that choice and the denial.
- The Eleventh Circuit reviewed for abuse of discretion (new-trial denial) and reviewed factual findings for clear error and legal conclusions de novo.
- The court affirmed: Prendergast failed to prove suppression or materiality under Brady or Giglio; the government had disclosed Benny’s name and connection pretrial; witnesses did not testify they had knowledge contradicting the defense theory.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Applicable materiality standard (Brady v. Maryland vs. Giglio v. United States) | District court should have applied Giglio (more defense-friendly) because alleged perjured testimony was involved | District court properly considered materiality and denial valid because defendant failed materiality under any standard | No reversible error in standard choice; defendant failed to show materiality under either standard |
| Suppression of Suresh Benny evidence | Government withheld existence of a fake passport in Benny case that would impeach witnesses and be favorable to defense | Government disclosed Benny’s name and the potential relation to Prendergast’s case before trial; no suppression | No suppression; government disclosed Benny information pretrial |
| Witness perjury / false testimony (Williams and Vila) | Their testimony was false and would have been impeached by Benny passport evidence | Witnesses did not testify to knowledge of what happened to Prendergast’s passport; no established false testimony | Defendant failed to conclusively show witnesses’ testimony was false; no Giglio relief |
Key Cases Cited
- Brady v. Maryland, 373 U.S. 83 (1963) (prosecution must disclose materially favorable evidence)
- Giglio v. United States, 405 U.S. 150 (1972) (prosecutor must correct known perjured testimony; materiality standard for Giglio)
- United States v. Stein, 846 F.3d 1135 (11th Cir. 2017) (defines Brady and Giglio elements and comparative materiality)
- United States v. Vallejo, 297 F.3d 1154 (11th Cir. 2002) (Brady elements)
- Maharaj v. Secretary for Dept. of Corrections, 432 F.3d 1292 (11th Cir. 2005) (defendant must conclusively show testimony was actually false)