Willie Jerome Manning v. State of Mississippi, 2015 Miss. LEXIS 79

Manning was convicted of murdering two elderly women in Starkville, Mississippi, and was sentenced to death; the only witness placing him entering the apartment was Kevin Lucious, a Missouri inmate convicted of multiple offenses.
Manning filed a post-conviction relief petition; the court granted relief on three grounds: withheld evidence, Lucious’s testimony, and ineffective assistance of counsel related to those claims.
The canvass of Brooksville Gardens Apartments produced cards showing the vacant status of the apartment Manning allegedly entered and that Lucious and his girlfriend Jones were not residents; these cards were not disclosed to Manning or his counsel.
The PCR court rejected recanted testimony and upheld trial court rulings on ineffective assistance; the State was found to have suppressed material evidence.
The Mississippi Supreme Court reversed, holding the State violated due process by withholding favorable, material evidence and remanded for a new trial; a dissenting opinion disagreed on whether the Savable canvass evidence established a Brady violation.
The case was remanded for a new trial; the opinion discusses the scope of Brady compliance, the responsibilities of prosecutors and investigators, and the credibility of witness recantations.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Brady violation due to suppression of favorable evidence	Manning argues the canvass cards were favorable and suppressed	State argues no material suppression; canvass notes lacked credibility	Brady violation established; suppression found and relief granted
Whether the evidence was material to the outcome	Disclosed evidence would have altered defense strategy	Evidence lacked material impact on verdict	Evidence was material; probability of different outcome supported relief
Effective assistance of counsel due to undisclosed evidence	Counsel was hamstrung by undisclosed favorable evidence	No prejudice shown; counsel performance not deficient	Counsel not deemed ineffective due to suppression of evidence (reconsidered with other grounds)
Admission of recanted testimony and credibility	Recantation undermines trial credibility and supports relief	Recantation unreliable; credibility largely for trial court	Court accepted prior credibility findings; recantation insufficient to change outcome
Due process rights to inspect law enforcement files	Manning denied access to investigative materials	Access not guaranteed to alter outcome	Brady analysis governs; due process violation found in disclosure failure

King v. State, 656 So.2d 1168 (Miss. 1995) (four-prong Brady test adopted (impeachment evidence, access, suppression, probability of different outcome))
Spagnoulo v. United States, 960 F.2d 990 (11th Cir. 1992) (definitive Brady framework; focuses on materiality and suppression)
Bagley v. United States, 473 U.S. 667 (U.S. 1985) (material evidence includes impeachment information; reasonable probability of different outcome)
Box v. State, 437 So.2d 19 (Miss. 1983) (justice enhanced when both sides have access to evidence)
Brady v. Maryland, 373 U.S. 83 (U.S. 1963) (prosecution withholding favorable evidence violates due process)
Agurs v. United States, 427 U.S. 97 (U.S. 1976) (withholding information relevant to guilt or punishment may be constitutional error depending on materiality)