Tiner v. Premo

A criminal defendant is entitled to post-conviction relief if the State withholds material evidence that is favorable to the defendant. Brady v. Maryland, 373 US 83 (1963).

Petitioner appealed a post-conviction judgment denying relief from his criminal trial in which a jury found him guilty of intentional murder and two counts of aggravated murder. Petitioner assigned error to the post-conviction ruling that undisclosed evidence was not material to the impeachment of two government witnesses. A criminal defendant’s due process rights are violated when a prosecutor withholds evidence favorable to the defendant. Brady v. Maryland, 373 US 83 (1963). “[T]here are three components of a true Brady violation: [1] the evidence must be favorable to the accused, either because it is exculpatory, or because it is impeaching; [2] that evidence must have been suppressed by the State, either willfully or inadvertently; and [3] prejudice must have ensued.” Strickler v. Greene, 527 US 263 (1999). The State conceded to the Brady violation in regards to two witnesses, but contended Petitioner was entitled to limited relief only of the aggravated murder verdicts. The Court held the post-conviction court erred when it did not grant relief on Petitioner’s Brady claims because the withheld information of two witnesses’ biases against Petitioner could have reasonably allowed the jury to acquit Petitioner of the aggravated murder charges. The withheld evidence was material only to the aggravated murder verdicts. Reversed and remanded with respect to Petitioner’s conviction for aggravated murder, otherwise affirmed.