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Law School Case Brief

People v. Jackson - 235 Cal. App. 3d 1670, 1 Cal. Rptr. 2d 778 (1991)

Rule:

The prosecution's duty to disclose extends to all evidence that reasonably appears favorable to the accused, not merely to that evidence which appears likely to affect the verdict. When the prosecution suppresses evidence which is material to guilt or punishment, regardless of whether that suppression is intentional or inadvertent, the defendant's due process rights are abridged.

Facts:

Defendant Kenneth Jackson, Jr., was convicted in California state court of attempted murder and of assault with a firearm due to a shooting incident in a university dance. The trial court found that the defendant personally used the firearm and did so with the intent to inflict great bodily injury. During trial, defendant contended that, although he was in possession of a gun at the time, another individual shot the victim with a different gun. This individual died in an unrelated incident prior to trial. Near the end of the trial, a witness advised the police that the deceased individual shot the victim, but the prosecutor did not disclose this statement until two weeks after the jury had rendered its verdict. Moreover, at trial, the court excluded other witnesses' testimony that the deceased individual had made self-incriminating statements and had made threats to defendant. Based on the aforementioned errors, defendant appealed his conviction arguing that the cumulative impact of these errors was to deny defendant a fair trial.

Issue:

Was the defendant denied of a fair trial, thereby necessitating the reversal of his conviction?

Answer:

Yes.

Conclusion:

The appellate court reversed defendant’s conviction, holding that the prosecution's suppression of the witness' statement prejudiced defendant, since the statement was material to defendant's defense, notwithstanding that there was no opportunity to investigate the witness' reliability. It also held that the trial court abused its discretion in excluding the witness' testimony as to the individual's statement, since the statement constituted a declaration against penal interest, and since the probative value of the evidence outweighed any prejudice. As to the evidence of the individual's threats, the court held that the evidence was admissible, since, if found credible, the evidence could have raised a reasonable doubt as to defendant's guilt.

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