Wearry v. Cain

The Louisiana Court failed to recognize and grant Appellant relief for a Brady v. Maryland violation committed by state prosecutors after they failed to turn over material evidence that prejudiced the appellant.

Appellant was convicted of capital murder and sentenced to death. Appellant later discovered that the prosecution withheld information. The prosecution did not disclose police records that cast doubt on the credibility of a key witness. The prosecution also failed to turn over medical records that would contradict the testimony of that witness. Additionally, the prosecution misrepresented the motive of a different witness. Appellant claimed that the prosecution committed a Brady violation and that his trial attorney failed to provide adequate assistance of counsel. The Louisiana Trial court and Supreme Court denied relief to both of Appellant's claims. Appellant's Brady violation was based off the precedent that “the suppression by the prosecution of evidence favorable to an accused upon request violates due process where the evidence is material either to guilt or to punishment, irrespective of the good faith or bad faith of the prosecution.” Brady v. Maryland, 373 U.S. 83 (1963). To prevail on his Brady claim, Appellant only had to show that “the new evidence is sufficient to ‘undermine confidence’ in the verdict.” Smith v. Cain, 132 S.Ct. 627 (2012). Applying this standard, the United States Supreme Court held that the new evidence was sufficient to undermine the confidence of the verdict. The Court found that the information would have undermined the prosecution’s case and materially aided Appellant at trial in violation of Appellant's Sixth Amendment and Due Process rights. In light of the Constitutional violation, the Court did not address the claim of ineffective assistance of counsel. REVERSED and REMANDED.