Youngblood v. West Virginia

PETITIONER: Denver A. Youngblood, Jr.
RESPONDENT: West Virginia
LOCATION: Supreme Court of Appeals of West Virginia

DOCKET NO.: 05-6997
DECIDED BY: Roberts Court (2006-2009)
LOWER COURT: Supreme Court of Appeals of West Virginia

CITATION: 547 US 867 (2006)
DECIDED: Jun 19, 2006
GRANTED: Jun 19, 2006

Facts of the case

Denver A. Youngblood, Jr. was indicted on charges relating to the alleged abduction and sexual assault of three young women. The prosecution’s case rested largely on the testimony of the young women and evidence consistent with their claims. The jury convicted Youngblood of sexual assault, brandishing a firearm, wanton endangerment involving a firearm, and indecent exposure. After being sentenced, Youngblood moved to set aside the verdict and argued that there was new and exculpatory evidence in the form of a note from two of the young women that supported Youngblood’s consensual-sex defense to the sexual assault charge. The note had allegedly been shown to a state trooper who was investigating the incident, but he had refused to accept possession of it and requested that it be destroyed. Youngblood claimed that the suppression of this evidence constituted a violation of his rights under Brady v. Maryland, which held that a constitutional violation occurs when the government fails to disclose evidence favorable to the accused. The trial court denied Youngblood a new trial by holding that the note was only impeachment, not exculpatory, evidence. The Supreme Court of Appeals of West Virginia affirmed by holding that the trial court had not abused its discretion in denying a new trial. The Supreme Court of Appeals did not reach a decision on the merits of the alleged Brady violation.

Question

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