Tuesday, November 5, 2013

Kyles v. Whitley case brief

Kyles v. Whitley case brief summary
514 U.S. 419 (1995)

Petitioner challenged a first-degree murder conviction claiming that the State failed to disclose evidence favorable to him. The Fifth Circuit Court of Appeals affirmed the denial of petitioner's habeas corpus petition, and petitioner was granted certiorari.

Petitioner was convicted of first-degree murder. He appealed, claiming that the State knew of evidence favorable to him before and during trial that it failed to disclose. The State supreme court remanded the case for an evidentiary hearing on defendant's claims of newly discovered evidence.

The trial court, after review, denied relief. The state supreme court denied petitioner's application for discretionary review. A petition for habeas corpus was then filed in district court, which denied the petition. The court of appeals affirmed by a divided vote.

The Supreme Court granted certiorari and reversed and ordered a new trial, holding that the net effect of the evidence withheld by the State in this case raised a reasonable probability that its disclosure would have produced a different result.


Petitioner's conviction was reversed and remanded for a new trial ordered because the omitted evidence favoring petitioner could have potentially resulted in a different verdict.

Recommended Supplements for Criminal Procedure Criminal Procedure: Examples & Explanations, Sixth Edition
Emanuel Law Outline: Criminal Procedure

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