Smith v. Cain
Issues
Whether evidence proffered by Smith, which he claims was suppressed and thus not available to the defense at trial, is material, and whether there is a reasonable possibility that this evidence could have affected the outcome of the trial.
Petitioner Juan Smith was the sole person convicted of killing five people in a Louisiana home. His conviction was primarily based on the testimony of a witness, a survivor of the shooting, who identified Smith as one of the gunmen responsible for the crime. In subsequent applications for review, Smith contended that his trial was unfair because the prosecution intentionally suppressed material evidence. In this case, Smith argues that the suppression of that evidence constituted a violation of his constitutional due process rights; he supports this argument by seeking to show that the suppressed evidence undermines confidence in the jury’s verdict against him. While Smith insists that he is entitled to a new trial, Respondent Burl Cain, warden of the Louisiana State Penitentiary, insists that the evidence was neither material nor suppressed, thus opposing a new trial. This case may affect the standard to which a prosecutor is held with regard to disclosure of evidence.
Questions as Framed for the Court by the Parties
In this criminal case, the state trial court, the Louisiana Fourth Circuit Court of Appeal, and the Louisiana Supreme Court, without making any factual findings, or providing any reasons for their rulings, denied Petitioner Juan Smith post-conviction relief. Smith contends that the state courts reached this result only by disregarding firmly established precedents of this Court regarding suppression of material evidence favorable to a defendant and presentation of false or misleading evidence by a prosecutor.
1. Is there a reasonable probability that, given the cumulative effect of the Brady and Napue/Giglio violations in Smith’s case, the outcome of the trial would have been different?
2. Did the Louisiana state courts ignore fundamental principles of due process in rejecting Smith’s Brady and Napue/Giglioclaims?
A Louisiana state court convicted Petitioner Juan Smith of participating in the 1995 shooting murder of five people, and sentenced Smith to life in prison without parole. See Brief for Petitioner, Juan Smith at 2; Brief for Respondent
Edited by
Additional Resources
New Orleans Times-Picayune: U.S. Supreme Court Rejects $14 Million Judgment Against New Orleans District Attorney’s Office (Mar. 29, 2011)
American Bar Association: Model Rule 3.8 Special Responsibilities of a Prosecutor
LII: Fourteenth Amendment