Youngblood v. West Virginia

Facts of the Case

Petitioner Denver A. Youngblood, Jr., was convicted in a West Virginia state court of two counts of sexual assault, two counts of brandishing a firearm, and one count of indecent exposure, principally on the basis of: (1) testimony of three women that they had been held captive by Youngblood and a friend of his, (2) statements by one of the woman that she had been forced at gunpoint to perform oral sex on Youngblood, and (3) evidence concerning asserted disposal of physical evidence of the alleged sexual encounter. Youngblood was sentenced to a combined term of 26 to 60 years’ imprisonment, with 25 to 60 of those years directly attributable to the sexual-assault convictions.

Question

Does the suppression of evidence favorable to the defense constitute a valid claim of a violation of constitutional rights under Brady v. Maryland ?

CONCLUSION

In a per curiam opinion, the majority of the Court held that Youngblood presented a valid constitutional claim under Brady v. Maryland by alleging that the state trooper suppressed evidence favorable to Youngblood’s defense. Because there was a valid claim of a Brady violation, the Supreme Court of Appeals of West Virginia should have addressed that issue on the merits. Therefore, the case was remanded.In his dissent, Justice Antonin Scalia wrote that the Supreme Court should have addressed the Brady issue on the merits rather than remanding the case to the lower court without guidance. Justice Clarence Thomas joined in the dissent. Justice Anthony M. Kennedy wrote a separate dissent in which he argued that remanding a case to a lower court for further explanation on the Brady issue was “both improper and contrary to our precedents.”

Case Information

  • Citation: 547 US 867 (2006)
  • Decided Jun 19, 2006Granted: Jun 19, 2006