Smith v. Cain

PETITIONER: Juan Smith
RESPONDENT: Burl Cain, Warden
LOCATION: Orleans Parish Criminal Court

DOCKET NO.: 10-8145
DECIDED BY: Roberts Court (2010-2016)
LOWER COURT: Louisiana Supreme Court

CITATION: 565 US (2012)
GRANTED: Jun 13, 2011
ARGUED: Nov 08, 2011
DECIDED: Jan 10, 2012

ADVOCATES:
Donna R. Andrieu - for the respondent
Kannon K. Shanmugam - for the petitioner

Facts of the case

Juan Smith was convicted on five counts of murder and sentenced to life in prison without parole. The Louisiana state trial court, Fourth Circuit Court of Appeal and state Supreme Court denied Smith's petition for review. Smith contends that the Louisiana state courts reached this result only by disregarding established precedents regarding the suppression of material evidence favorable to a defendant and presentation of false or misleading evidence to a prosecutor in past Supreme Court cases, Brady v. Maryland, Giglio v. United States and Napue v. Illinois.

Question

Was there a reasonable probability that the outcome would have been different if the undisclosed witness statements were presented at trial?

Did the State of Louisiana ignore due process by rejecting Smith's Brady claim?

Media for Smith v. Cain

Audio Transcription for Oral Argument - November 08, 2011 in Smith v. Cain

Audio Transcription for Opinion Announcement - January 10, 2012 in Smith v. Cain

John G. Roberts, Jr.:

I have the opinion of the Court this morning in case 10-8145, Juan Smith versus Burl Cain.

Juan Smith was convicted of murdering five people during an armed robbery.

At Smith's trial, a single eyewitness linked Smith to the crime.

No other witnesses and no physical evidence implicated Smith.

Smith later obtained files from the police investigation of the crime.

Those files showed that the key eyewitness had told the police among other things that he “could not ID anyone because he could not see their faces” and that he “would not know them if he saw them."

The witness nonetheless had confidently identified Smith in Court.

In 1963, we decided a case called Brady versus Maryland.

In that case, we explained that prosecutors may not withhold from criminal defendants evidence that is favorable to the defence and material to determining the defendant's guilt or innocence.

The State in this case acknowledges as it must that the witness' statements were not given to Smith and that those statements were helpful to him.

The only question, therefore, is whether the statements were material.

We have said that statements are material if there is a “reasonable probability' that the result of the trial would have been different had the evidence been disclosed.

Now, when the only evidence linking a defendant to a crime is an identification by a single eyewitness and that witness had previously told the police that he could not ID anyone because he could not see their faces, it's pretty clear that the withheld evidence is material.

The State contends that the jury might have disregarded Smith's undisclosed statements because the witness had also -- the statements that weren't disclosed to Smith because the witness had also told police shortly after the crime that he could make an identification of one of the shooters.

According to the State, the witness' statement that he could not see the perpetrators' faces meant that he could not see the faces of perpetrators other than the one he could identify and the State claims that the witness' later statement that he would not know the perpetrators if he saw them can be explained by his legitimate fear of possible retaliation, but all that only leaves as to speculate about which of the witness' contradictory statements the jury would have believed, the statements in which the witness said he could identify Smith or those in which he said he could not.

Because there is a reasonable probability that the jury would have believed the witness' statements that he could not identify Smith, we can have no confidence in Smith's conviction.

The judgment of the Orleans Parish Criminal District Court of Louisiana is accordingly reversed.

Justice Thomas has filed a dissenting opinion.

Sarah from Law Aspect

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