State v. J.D.B.

Even in juvenile proceedings, “it is a fundamental violation of due process for the state to withhold evidence that is favorable to an accused where the evidence is material to either guilt or punishment.” Brady v. Maryland, 373 US 83, 87 S Ct 1194, 10 L Ed 2d 215 (1963).

J.D.B. (“Youth”) appealed a judgment finding him within the juvenile court’s jurisdiction after he stabbed the victim (“D”). Youth assigned error to the juvenile court’s denial of his motion to dismiss. Youth argued that the state violated his Brady rights when they failed to inform him that they were in possession of material that substantiated his sexual abuse allegations against D, claiming the information was essential to his defense. Even in juvenile proceedings, “it is a fundamental violation of due process for the state to withhold evidence that is favorable to an accused where the evidence is material to either guilt or punishment.” Brady v. Maryland, 373 US 83, 87 S Ct 1194, 10 L Ed 2d 215 (1963). The Court reasoned that the evidence of abuse was material to Youth’s claim of self-defense because it was relevant to his subjective fear when he committed the violent act. The Court found that the state reasonably should have anticipated that they would be in possession of the material during Youth’s proceedings, and therefore had a duty to disclose it. However, due to a lack of evidence that misconduct during trial could not be cured by anything except a dismissal, the Court declined to dismiss. Reversed and remanded.