Supreme Court Tosses Murder Conviction for Brady Violation by New Orleans DA
The U.S. Supreme Court has overturned a murder conviction obtained by New Orleans prosecutors because the defense didn’t receive important exculpatory evidence before the trial.
The court ruled 8-1 on behalf of Juan Smith, convicted of five murders on the strength of testimony by a single witness who identified Smith as the first gunman to come through the door during a robbery. The witness had earlier told a detective that he could not identify the perpetrators, but notes recounting the conversation were not disclosed in Smith’s trial.
Chief Justice John G. Roberts Jr. wrote the four-page majority opinion (PDF) finding the conviction must be overturned because the undisclosed evidence was material under standards set by Brady v. Maryland. The lone dissent by Justice Clarence Thomas, on the other hand, spanned 19 pages. Thomas noted the witness had identified Smith after seeing his photo in an array presented by police. “This is it,” the witness had said. “I’ll never forget that face.”
The ruling today in Smith v. Cain follows a Supreme Court decision last year on behalf of New Orleans prosecutors. The 2011 decision in Connick v. Thompson overturned a $14 million award to a death row inmate who alleged prosecutors withheld exculpatory blood evidence in his trial for attempted armed robbery, leading to a conviction and ramifications in a later murder case. Observers had speculated the Supreme Court granted cert in Smith v. Cain to focus on New Orleans prosecutors after the 2011 decision. There was no circuit split and no new legal issue in the case, according to prior press coverage.
The ABA had filed an amicus brief in the new case arguing that prosecutors’ ethical obligations to disclose exculpatory evidence before trial are separate from and broader than the constitutional standards established in Brady v. Maryland.