Overton v. U.S.

Posted: February 3, 2017 by beguide in case summaries, Criminal Procedure, Due Process, White Skull

a_002WHAT HAPPENED:  Defendant was convicted of murder in 1985, after being accused of assaulting a middle-aged woman who was coming back from shopping.  Defendant is appealing his conviction on grounds that the prosecutors failed to disclose material impeachment and exculpatory evidence during the original trial.  The evidence included evidence that contradicted the State’s argument that the assault was carried out by a large group of assailants, as opposed to just a few assailants.

WHY IS THIS BEFORE THE SUPREME COURT:  In Brady v. Maryland, the Supreme Court held that the prosecutor must disclose material information that could lead to an acquittal to the defendant prior to trial.  This responsibility is founded in the Due Process Clause of the Constitution and is rooted in fairness, since the State often receives more information than the Defendant and has a duty to society to share information that may indicate that the charges are unfounded.  In order to satisfy that burden, the defendant must show that the evidence was material, in that it the evidence would have changed the outcome had it been shared.  The nuance in this case is that standard that the Court must apply when determining whether evidence is “material” or not, as the Court held that the Defendant could only win if he could prove that the suppressed evidence “would have led the jury to doubt virtually everything” about the government’s case.  That instructions seems high without context, but it does speak to the high level of scrutiny the Court places on these types of arguments.

WHAT ARE THE RAMIFICATIONS – This case is less interesting (from a legal standpoint) than its 2017 Brady case counterpart, Turner v. U.S..  In Turner, the Defendant is asking to move the law forward and develop the materiality test to consider a wider scope of evidence.  Here, the Court is really just asking whether or not this Court applied the correct standard of review on appeal, which is less sexy than Turner, but this defendant probably has a better chance to win on more narrow grounds.  That being said, Brady cases are difficult to win due to their implications, so even though this defendant may have a better chance, that doesn’t mean he has a great chance.

ROOT FOR OVERTON IF:  your idea of a good time is considering the impact of pattern form jury instructions.

ROOT FOR U.S. IF:  you think this case would be a lot more interesting if it got the Ira Glass treatment.

PREDICTION:  U.S. wins 5-3

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