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United States v. Cuffie - 317 U.S. App. D.C. 38, 80 F.3d 514 (1996)


Evidence is material if the undisclosed information could have substantially affected the efforts of defense counsel to impeach the witness, thereby calling into question the fairness of the ultimate verdict.


Defendant John A. Cuffie was convicted in federal district court of possession with intent to distribute cocaine base and conspiracy to possess and distribute cocaine base. Cuffie filed a motion for a new trial, contending that the Government failed to disclose favorable evidence under Brady v. Maryland. Specifically, Cuffie claimed that Government did not inform Cuffie that a key witness against him at trial, Ronald F. Moore, had perjured himself in another judicial proceeding. The district court denied the motion. Cuffie appealed.


Was the undisclosed information material?




The appellate court reversed the district court's judgment and remanded the case to that court for a new trial. The court held that the information was material because a cross-examination of the witness could have revealed evidence casting serious doubt on the his truthfulness. Although the jury was presented with other reasons not to believe the witness, the court held that perjury was an entirely different factor. There was a reasonable probability that the verdict would have been different if Cuffie had been able to use the undisclosed evidence to impeach the witness at trial, and thus reversal was required.

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