JURIST - Paper Chase: Supreme Court overturns conviction due to DA withholding evidence

[JURIST] The US Supreme Court [official website] ruled 8-1 [opinion, PDF] Tuesday in Smith v. Cain [JURIST report] to overturn the conviction of Juan Smith due to the New Orleans District Attorney's office [official website] withholding material evidence from the defense. Smith was convicted of murder largely on the testimony of one eyewitness. However, the District Attorney's office had statements from the witness that indicated he had not properly identified Smith, which was not turned over to Smith and his defense during the proceedings. Chief Justice John Roberts explained that this was a clear violation of Brady v. Maryland [text] as the case rested solely on the eyewitness' credibility:

We have observed that evidence impeaching an eyewitness may not be material if the State's testimony was the only evidence linking Smith to the crime. And Boatner's undisclosed statements directly contradict his testimony: Boatner told the jury that he had "[n]o doubt" that Smith was the gunman he stood "face to face" with on the night of the crime, but [the police detective's] notes show Boatner saying that he "could not ID anyone because [he] couldn't see faces" and "would not know them if [he] saw them." Boatner's undisclosed statements were plainly material.

Other allegations of prosecutorial misconduct in this case were not ruled on, as this instance of withholding evidence was sufficient to overturn the conviction. In dissent, Justice Clarence Thomas argued that the state had adequately convicted Smith without the eyewitness testimony.

Smith v. Cain is only the latest of several allegations of prosecutorial misconduct [SCOTUSblog backgrounder] out of the New Orleans District Attorney's office. This scrutiny has been ongoing for 15 years, beginning with Kyles v. Whitley [text], as the New Orleans District Attorney's office continues a policy of withholding exculpatory evidence from the defense. Last term, a divided court ruled in Connick v. Thompson [JURIST report] that District Attorney Harry Connick Sr.'s failure to train subordinates in properly handling evidence could not result in a civil suit. As in Smith v. Cain, Thompson was convicted due to Connick's office not releasing exculpatory evidence to the defense.