Sunday, November 3, 2013

Smith v. Cain case brief

Smith v. Cain case brief summary
132 S.Ct. 627 (2012)

Petitioner inmate sought postconviction relief regarding his first-degree murder conviction, alleging a Brady violation. The Orleans Parish Criminal District Court of Louisiana rejected the Brady claim, and the Louisiana Court of Appeal and Louisiana Supreme Court denied review. The United States Supreme Court granted certiorari.

The inmate was charged with killing five people during an armed robbery. At trial, a witness identified the inmate as the first gunman to come through the door. No other witnesses and no physical evidence implicated the inmate in the crime. After being convicted, the inmate obtained a detective's notes, which contained statements by the witness that conflicted with his testimony identifying the inmate as a perpetrator. The inmate alleged that the prosecution's failure to disclose the detective's notes violated Brady.


  • The Court determined that the witness's undisclosed statements alone sufficed to undermine confidence in the inmate's conviction because the undisclosed statements were plainly material to the determination of the inmate's guilt since the witness's testimony was the only evidence linking the inmate to the crime, and the witness's undisclosed statements directly contradicted the witness's testimony.


The Court reversed the state trial court's judgment and remanded the case for further proceedings. 8-1 Decision; 1 Dissent.

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

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