Criminal Justice Case Brief free essay sample

Maddox v. Montgomery United States Courts of Appeals, Eleventh Circuit 718 F. 2d 1033 (11th Cir. 1983) Kenneth Davis CJAD 405, Section A Professor Alesio June 08, 2011 Facts: Jimmy Maddox was convicted of rape in a Georgia state court and sentenced to life imprisonment. Having unsuccessfully pursued his direct appeal and the state post-conviction remedy, Maddox filed a federal habeas corpus petition alleging prosecutorial suppression of exculpatory evidence in violation of the doctrine of Brady v. Maryland. There are four types of situations in which the Brady doctrine applies; the prosecutor has not disclosed information despite a specific defense request, the prosecutor has not disclosed information despite a general defense request for all exculpatory information or without any defense request at all, the prosecutor knows or should know that the conviction is based on false evidence and or the prosecutor fails to disclose purely impeaching evidence not concerning a substantive issue, in the absence of a specific defense request. We will write a custom essay sample on Criminal Justice Case Brief or any similar topic specifically for you Do Not WasteYour Time HIRE WRITER Only 13.90 / page Issue: Specifically, Maddox asserted that his right to due process was violated as outlined in violation of the doctrine of Brady v. Maryland by the states failure to disclose a photograph taken by the police shortly after the alleged rape showing Elders bed neatly made, the results of a police examination of the bedspread which revealed no blood, semen or other fluid, and lastly a written statement by another witness, Brenda Phelps, that Debbie Phillips had stated that she dropped her insurance with Maddox for financial reasons. Maddox appeals the denial of habeas relief. Decision of the Court: The United States Court of appeals ruled that if the suppressed evidence is purely impeaching evidence and no defense request has been made, the suppressed evidence is material only if its introduction probably would have resulted in acquittal. Given the relatively minor role of Phillips testimony and the limited impact that Phelps statement would likely have had on the jurys assessment of Phillips credibility, Maddox is unable to demonstrate that the undisclosed evidence probably would have resulted in an acquittal. Also, the evidence is immaterial under Blasco, and its suppression did not violate Maddox’s due process right. For the foregoing reasons, the district courts dismissal of Maddoxs habeas petition is affirmed. Reasoning of the Court: The United States Court of Appeals first determined that Brady doctrine did not apply because Maddox defense did not request the information be disclosed in a specific request. It was only after unsuccessfully pursuing his direct appeal did he bring up this post conviction habeas corpus petition. In the United States v. Agurs the Court stated that such a failure to disclose violates due process only if the omitted evidence creates a reasonable doubt that did not otherwise exist. Similarly the results of the police examination of the bedspread do not give rise to a reasonable doubt and again are immaterial under, Agurs. Lastly, the Court ruled that the information is merely consistent with Maddox’s version of the incident and scarcely contradicts the alleged victim’s testimony, and in view of the substantial inculpatory evidence in the record, the evidence at issue is not sufficiently material to render the state’s failure to disclose unconstitutional. Citations to Support Judgment: Brady v. Maryland, 373 U. S. 83 (1963). United States v. Anderson, 574 (5th Cir. 1978). United States v. Kopituk, 690, 1289, 1339 (11th Cir. 1982). United States v. Kubiak 1551, (11th Cir. 1983). United States v. Blasco, 464, U. S. 914, (1983).