76 N.Y.2d 67 (1990)
Defendant was convicted of various arson crimes. He challenged his conviction, contending that he was entitled to a new trial because the prosecution improperly withheld exculpatory evidence from his defense counsel. The lower court granted his motion for a new trial. The prosecution challenged the decision, contending that the motion was improper because it should have been raised on direct appeal.
- The court rejected the prosecution's contention, finding that defendant was entitled to a new trial because there was a reasonable possibility the exculpatory evidence that had not been disclosed contributed to defendant's conviction.
- The court ruled that the evidence was material because it was a report that the a bomb had never exploded.
- The court noted that other defendants associated with the same crime were acquitted.
The court affirmed the lower court's decision granting defendant a new trial. The court held that there was a reasonable probability that the undisclosed evidence might have led to a different trial strategy that would have resulted in a different outcome.
Recommended Supplements for Criminal Procedure Criminal Procedure: Examples & Explanations, Sixth Edition
Emanuel Law Outline: Criminal Procedure