Law School Case Brief
Monroe v. Angelone - 323 F.3d 286 (4th Cir. 2003)
The prosecution's failure to disclose evidence favorable to an accused violates due process where the evidence is material either to guilt or to punishment, irrespective of the good faith or bad faith of the prosecution. Moreover, the prosecutor's duty encompasses both impeachment material and exculpatory evidence, and it includes material that is "known only to police investigators and not to the prosecutor." Along these lines, the individual prosecutor has a duty to learn of any favorable evidence known to the others acting on the government's behalf. Significantly, a Brady violation has three essential elements: (1) the evidence must be favorable to the accused; (2) it must have been suppressed by the government, either willfully or inadvertently; and (3) the suppression must have been material, i.e., it must have prejudiced the defense at trial.
In March of 1992, wealthy art collector and notorious philanderer Roger de la Burde died from a single gunshot wound to the head. Following a high-profile trial in Powhatan County, Virginia, his longtime girlfriend Beverly Monroe was convicted of his murder. Monroe later discovered a wealth of exculpatory evidence that the prosecution had suppressed, including impeachment material, leads implicating other suspects, official documents labeling Burde's death a suicide, and statements suggesting that Burde may have been suicidal. On the basis of this new information, Monroe claimed that the prosecution had violated her due process rights, pursuant to the principles established by Brady v. Maryland. After unsuccessful state court proceedings, Monroe petitioned for a writ of habeas corpus in the Eastern District of Virginia. Following discovery in the federal proceedings, the district court granted the writ, concluding that the prosecution had suppressed material, exculpatory evidence. The Commonwealth appealed the court's award of habeas corpus relief, and Monroe cross-appealed, challenging the court's conclusion that she procedurally defaulted certain aspects of her Brady claim.
In light of the discovery of the suppressed evidence, was the district court correct in granting Monroe's petition for habeas corpus?
The appellate court held that the first-degree murder case was tenuous. The evidence was circumstantial, and Monroe presented a strong defense. The court examined the habeas evidence collectively, rather than item by item. According to the court, had the evidence been available at trial, it would have further undermined an already marginal first-degree murder prosecution and would have undermined the Commonwealth's proof of premeditation and malice. To exemplify, the court said that absent evidence of two deals between the Commonwealth and the key witness, Monroe was unable to effectively counter the Commonwealth's portrayal of this witness as trustworthy.
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