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Law School Case Brief

Youngblood v. West Virginia - 547 U.S. 867, 126 S. Ct. 2188 (2006)

Rule:

A Brady violation occurs when the government fails to disclose evidence materially favorable to the accused. The Brady duty extends to impeachment evidence as well as exculpatory evidence, and suppression occurs when the government fails to turn over even evidence that is known only to police investigators and not to the prosecutor. Such evidence is material if there is a reasonable probability that, had the evidence been disclosed to the defense, the result of the proceeding would have been different, although a showing of materiality does not require demonstration by a preponderance that disclosure of the suppressed evidence would have resulted ultimately in the defendant's acquittal. The reversal of a conviction is required upon a showing that the favorable evidence could reasonably be taken to put the whole case in such a different light as to undermine confidence in the verdict.

Facts:

Petitioner Denver A. Youngblood, Jr., was convicted in a West Virginia state court of two counts of sexual assault, two counts of brandishing a firearm, and one count of indecent exposure, principally on the basis of: (1) testimony of three women that they had been held captive by Youngblood and a friend of his, (2) statements by one of the woman that she had been forced at gunpoint to perform oral sex on Youngblood, and (3) evidence concerning asserted disposal of physical evidence of the alleged sexual encounter. Youngblood was sentenced to a combined term of 26 to 60 years' imprisonment, with 25 to 60 of those years directly attributable to the sexual-assault convictions.

Several months after being sentenced, Youngblood moved to set aside the verdict on the basis that an investigator working on his case had uncovered new and exculpatory evidence in the form of a graphically explicit note that squarely contradicted the state's account of the incidents in question and directly supported Youngblood's consensual-sex defense. This note was said to have been shown to a state trooper who allegedly had read the note but declined to take possession of it and told the person who produced it to destroy it.

Youngblood argued that the suppression of the purportedly exculpatory evidence violated the state's federal constitutional obligation, under Brady v. Maryland (1963) 373 U.S. 83, 83 S. Ct. 1194, 10 L. Ed. 2d 215, to disclose evidence favorable to the defense. However, the trial court denied Youngblood a new trial, and the Supreme Court of Appeals of West Virginia—in a bare majority decision in which the dissent, but not the majority, examined the Brady issue—affirmed the trial court's judgment.

Issue:

Did Youngblood present a federal constitutional Brady claim to the state supreme court?

Answer:

Yes.

Conclusion:

The case was remanded for the views of the full state supreme court on the Brady issue that Youngblood clearly presented. A Brady violation occurs when the government fails to disclose evidence materially favorable to an accused. Brady extends to impeachment evidence, and Brady suppression occurs even when the evidence not turned over is "known only to police investigators and not to the prosecutor." Reversal is required upon a "showing that the favorable evidence could reasonably be taken to put the whole case in such a different light as to undermine confidence in the verdict." Youngblood clearly presented a federal constitutional Brady claim to the state supreme court. 

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