| Smith v. Cain | |
|---|---|
 | |
| Full case name | Smith v. Cain |
| Citations | 565 U.S. 73 ( more ) |
| Case opinions | |
| Majority | Roberts, joined by Scalia, Kennedy, Ginsburg, Breyer, Alito, Sotomayor, Kagan |
| Dissent | Thomas |
| Laws applied | |
| U.S. Const. amend. XIV | |
Smith v. Cain, 565 U.S. 73, 132 S. Ct. 627 (2012), is a United States Supreme Court decision clarifying the Brady v. Maryland standard for criminal discovery. [1] Joshua Dressler has called Smith v. Cain the "most recent pronouncement on the discovery issue." [2]
The defendant, Juan Smith, was convicted of murdering five people during an armed robbery based upon the testimony of a single witness. [3] Smith appealed the verdict because the prosecution failed to disclose statements made by that witness to an investigator prior to trial that the witness: [3]
All Louisiana state courts rejected Smith's appeal and the Supreme Court granted certiorari. [3]
The issue before the Court was whether or not the suppressed statements by the sole witness were material under Brady v. Maryland. If so, the prosecution had violated Smith's due process rights. [3] The Court held that they were. [3]
The Court began its analysis recounting the standard on materiality set forth in United States v. Bagley , which states that evidence is material when "there is a reasonable probability that, had the evidence been disclosed, the result of the proceeding would have been different." [1] As the Court explained, quoting Kyles v. Whitley , the "reasonable probability" standard looks to whether "the likelihood of a different result is great enough to 'undermine confidence in the outcome of the trial.'” [3]
The Court stated that the witness's statements were "plainly material," because they were the only evidence linking the defendant to the crime. [3]
The Sixth Amendment to the United States Constitution sets forth rights related to criminal prosecutions. It was ratified in 1791 as part of the United States Bill of Rights. The Supreme Court has applied all but one of this amendment's protections to the states through the Due Process Clause of the Fourteenth Amendment.
Criminal procedure is the adjudication process of the criminal law. While criminal procedure differs dramatically by jurisdiction, the process generally begins with a formal criminal charge with the person on trial either being free on bail or incarcerated, and results in the conviction or acquittal of the defendant. Criminal procedure can be either in form of inquisitorial or adversarial criminal procedure.
In a legal dispute, one party has the burden of proof to show that they are correct, while the other party has no such burden and is presumed to be correct. The burden of proof requires a party to produce evidence to establish the truth of facts needed to satisfy all the required legal elements of the dispute.
Discovery, in the law of common law jurisdictions, is a phase of pretrial procedure in a lawsuit in which each party, through the law of civil procedure, can obtain evidence from other parties by means of methods of discovery such as interrogatories, requests for production of documents, requests for admissions and depositions. Discovery can be obtained from nonparties using subpoenas. When a discovery request is objected to, the requesting party may seek the assistance of the court by filing a motion to compel discovery. Conversely, a party or nonparty resisting discovery can seek the assistance of the court by filing a motion for a protective order.
In the legal system of the United States, a Brady disclosure consists of exculpatory or impeaching information and evidence that is material to the guilt or innocence or to the punishment of a defendant. The term comes from the 1963 U.S. Supreme Court case Brady v. Maryland, in which the Supreme Court ruled that suppression by the prosecution of evidence favorable to a defendant who has requested it violates due process.
Beyond (a) reasonable doubt is a legal standard of proof required to validate a criminal conviction in most adversarial legal systems. It is a higher standard of proof than the standard of balance of probabilities commonly used in civil cases because the stakes are much higher in a criminal case: a person found guilty can be deprived of liberty, or in extreme cases, life, as well as suffering the collateral consequences and social stigma attached to a conviction. The prosecution is tasked with providing evidence that establishes guilt beyond a reasonable doubt in order to get a conviction; albeit prosecution may fail to complete such task, the trier-of-fact's acceptance that guilt has been proven beyond a reasonable doubt will in theory lead to conviction of the defendant. A failure for the trier-of-fact to accept that the standard of proof of guilt beyond a reasonable doubt has been met thus entitles the accused to an acquittal. This standard of proof is widely accepted in many criminal justice systems, and its origin can be traced to Blackstone's ratio, "It is better that ten guilty persons escape than that one innocent suffer."
Exculpatory evidence is evidence favorable to the defendant in a criminal trial that exonerates or tends to exonerate the defendant of guilt. It is the opposite of inculpatory evidence, which tends to present guilt.
Brady v. Maryland, 373 U.S. 83 (1963), was a landmark United States Supreme Court case that established that the prosecution must turn over all evidence that might exonerate the defendant to the defense. The prosecution failed to do so for Brady, and he was convicted. Brady challenged his conviction, arguing it had been contrary to the Due Process Clause of the Fourteenth Amendment to the United States Constitution.
The Confrontation Clause of the Sixth Amendment to the United States Constitution provides that "in all criminal prosecutions, the accused shall enjoy the right…to be confronted with the witnesses against him." The right only applies to criminal prosecutions, not civil cases or other proceedings. Generally, the right is to have a face-to-face confrontation with witnesses who are offering testimonial evidence against the accused in the form of cross-examination during a trial. The Fourteenth Amendment makes the right to confrontation applicable to the states and not just the federal government.
Strickland v. Washington, 466 U.S. 668 (1984), was a landmark Supreme Court case that established the standard for determining when a criminal defendant's Sixth Amendment right to counsel is violated by that counsel's inadequate performance.
In the United States, the Jencks Act requires the prosecutor to produce a verbatim statement or report made by a government witness or prospective government witness, but only after the witness has testified.
United States criminal procedure derives from several sources of law: the baseline protections of the United States Constitution; federal and state statutes; federal and state rules of criminal procedure ; and state and federal case law. Criminal procedures are distinct from civil procedures in the US.
Kyles v. Whitley, 514 U.S. 419 (1995), is a United States Supreme Court case that held that a prosecutor has an affirmative duty to disclose evidence favorable to a defendant pursuant to Brady v. Maryland and United States v. Bagley.
In United States criminal procedure, the Federal government and certain states have reciprocal discovery laws that compel defendants to disclose some information to prosecutors before trial. Within the federal court system, this material is referred to as reverse Jencks Act material, after the United States Supreme Court case which established the principle, Jencks v. United States.
The United States Constitution contains several provisions regarding the law of criminal procedure.
Bell v. Cone, 535 U.S. 685 (2002), was a Supreme Court of the United States case that upheld a death sentence despite the defendant's argument that he should not be sentenced to death because he was suffering from drug-induced psychosis when he committed the crimes. Cone also argued that he was denied effective assistance of counsel because his attorney failed to present sufficient mitigating evidence during the sentencing phase of his trial and that his attorney inappropriately waived his final argument during the sentencing phase. In an 8–1 opinion written by Chief Justice William Rehnquist, the United States Supreme Court denied Cone's petition for a writ of habeas corpus. The Court held that the actions taken by Cone's attorney during the sentencing phase were "tactical decisions" and that the state courts that denied Cone's appeals did not unreasonably apply clearly established law. Justice John Paul Stevens wrote a dissenting opinion in which he argued that Cone was denied effective assistance of counsel because his attorney failed to "subject the prosecution's case to meaningful adversarial testing."
The Evidence Act 2006 is an Act of the Parliament of New Zealand that codifies the laws of evidence. When enacted, the Act drew together the common law and statutory provisions relating to evidence into one comprehensive scheme, replacing most of the previous evidence law on the admissibility and use of evidence in court proceedings.
Burks v. United States, 437 U.S. 1 (1978), is a United States Supreme Court decision that clarified both the scope of the protection against double jeopardy provided by the Fifth Amendment to the United States Constitution and the limits of an appellate court's discretion to fashion a remedy under section 2106 of Title 28 to the United States Code. It established the constitutional rule that where an appellate court reverses a criminal conviction on the ground that the prosecution failed to present sufficient evidence to prove the defendant's guilt beyond a reasonable doubt, the Double Jeopardy Clause shields the defendant from a second prosecution for the same offense. Notwithstanding the power that appellate courts have under section 2106 to "remand the cause and direct the entry of such appropriate judgment, decree, or order, or require such further proceedings to be had as may be just under the circumstances," a court that reverses a conviction for insufficiency of the evidence may not allow the lower court a choice on remand between acquitting the defendant and ordering a new trial. The "only 'just' remedy" in this situation, the Court held, is to order an acquittal.
Napue v. Illinois, 360 U.S. 264 (1959), was a United States Supreme Court case in which the Court held that the knowing use of false testimony by a prosecutor in a criminal case violates the Due Process Clause of the Fourteenth Amendment to the United States Constitution, even if the testimony affects only the credibility of the witness and does not directly relate to the innocence or guilt of the defendant.
United States v. Bagley, 473 U.S. 667 (1985), was a Supreme Court of the United States case that established the standard for materiality under Brady v. Maryland.