In Smith v. Cain, the Supreme Court just issued a ruling holding that one New Orleans man’s murder conviction must be reversed because prosecutors failed to mention that the sole eyewitness to the crime had earlier admitted to not being able to identify the killer.
The decision was overwhelming, 8-1, with Justice Clarence Thomas serving as the only dissenter. The case highlights a problem of prosecutors’ hiding potentially damaging evidence. The Court also called attention to the guarantee that the government must turn over evidence that may be favorable to a defendant. Such a guarantee arose in the 1963 Supreme Court decision Brady v. Maryland.
Chief Justice Roberts, writing for the majority, stated that, “We have observed that evidence impeaching an eyewitness may not be material if the state’s other evidence is strong enough to sustain confidence in the verdict.” He continued by adding, “That is not the case here.”
The case concerns Juan Smith who was charged with killing five people during a 1995 armed robbery of a New Orleans home. A single eyewitness, Larry Boatner, identified Smith as being involved in the killings. Boatner testified at trial that he had been “face to face with Smith during the initial moments of the robbery.”
Later, during a jury trial, Smith was convicted of five counts of murder. On appeal, Smith obtained files that showed that Boatner had told police on the night of the killings that he “could not ID anyone because (he) couldn't see faces.” Prosecutors failed to turn over the potentially devastating detective’s report to Smith before trial.
While weighing whether the information ought to have been revealed Roberts discussed Brady v. Maryland, which requires prosecutors to turn over evidence that would be favorable to the defendant and “material” to his guilt or punishment.
The Court held that Boatner’s comments met that burden. “Boatner's testimony was the only evidence linking Smith to the crime. And Boatner’s undisclosed statements directly contradict his testimony.”
In his lengthy dissent Thomas said that Boatner’s earlier statement confessing doubt about the killer’s identity did not undermine Boatner’s ultimate confidence in his identification of Smith at trial. “Much of the record evidence confirms that, from the night of the murders through trial, Boatner consistently described - with one understandable exception - the first perpetrator through the door, that Boatner's description matched Smith.” Smith would likely take issue with the idea that the “one understandable exception” was not, according to Justice Thomas, a very big deal.
Read: “Supreme Court Tosses Murder Conviction for Brady Violation by New Orleans DA,” by Debra Cassens Weiss, published at ABAJournal.com.
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