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Law School Case Brief

People v. Wright - 86 N.Y.2d 591, 635 N.Y.S.2d 136, 658 N.E.2d 1009 (1995)

Rule:

The mandate of Brady extends beyond any particular prosecutor's actual knowledge. Furthermore, the individual prosecutor has a duty to learn of any favorable evidence known to the others acting on the government's behalf in the case, including the police. The People therefore are not relieved of their obligation to turn over Brady material by the trial prosecutor's failure to discover that the police were in possession of exculpatory information.

Facts:

Appellant-defendant Vicki-Crystal A. Wright met Fred Washington at the Bottom's Up bar in Albany. They talked and had several drinks before going to Wright's apartment where she stabbed Washington when he was naked. At trial, Wright alleged that Washington surprised her by coming into her bedroom naked and attempting to rape her. Washington alleged that he had undressed in the bedroom in Wright's presence, then Wright went out, came back and stabbed him. The police reports indicated that some of Washington's clothes were found outside the bedroom, but the police testified at trial that the clothes were found in the bedroom. After being convicted of assault, Wright learned that Washington was a police informant. She filed a motion to vacate under N.Y. Crim. Proc. Law § 440.10, which was denied.

Issue:

Was the information that Washington was a police informant required to be disclosed by the prosecution to criminal defendant Wright?

Answer:

Yes

Conclusion:

The Court of Appeals of New York held that because Washington's status as a police informant was a motive for the police to corroborate him, that information was Brady information that had to be disclosed to Wright. Because the outcome of the case depended on the credibility of witnesses, the information was material. Under the circumstances, Washington's history as a police informant was both favorable and material to the defense, and therefore the People's failure meet their affirmative duty of disclosing this information to the defense violated defendant's constitutional right to due process. The Court reversed the order of the appellate court and dismissed the indictment without prejudice. The Court explained that the prosecution has an affirmative duty to disclose to the defense evidence in its possession that is both favorable to the defense and material to guilt or punishment. 

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