Strickler v. Greene
527 U.S. 263 (1999)
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Rule of Law:
To establish a constitutional violation under Brady v. Maryland, a defendant must show that the prosecution suppressed favorable evidence and that there is a reasonable probability that the outcome of the trial would have been different had the evidence been disclosed. The same standard of prejudice applies when a defendant seeks to excuse a procedural default for failing to raise the Brady claim in state court.
Facts:
- On January 5, 1990, Leanne Whitlock was abducted from a shopping mall, robbed, and murdered.
- Tommy Strickler and his companion, Ronald Henderson, were seen at the mall that afternoon.
- A witness, Kurt Massie, identified Strickler driving Whitlock's car near the cornfield where her body was later found.
- Strickler and Henderson were later seen at a bar where Henderson gave away Whitlock's watch.
- Another woman, Donna Tudor, testified that she was with Strickler after the murder, that he made incriminating statements, and that he was in possession of Whitlock's car and personal items.
- Whitlock's body was discovered near a 69-pound, blood-stained rock, which was believed to be the murder weapon.
- At trial, eyewitness Anne Stoltzfus gave a detailed and confident testimony describing Strickler as the aggressive leader who violently abducted Whitlock from the mall parking lot.
Procedural Posture:
- Strickler was convicted of capital murder in Virginia state trial court (Augusta County Circuit Court) and sentenced to death.
- The Virginia Supreme Court affirmed the conviction and sentence on direct appeal.
- Strickler filed a petition for a writ of habeas corpus in state court, which was dismissed. The Virginia Supreme Court affirmed the dismissal.
- Strickler filed a federal habeas corpus petition in the U.S. District Court for the Eastern District of Virginia.
- The District Court ordered the prosecution to produce its files, which led to the discovery of the suppressed impeachment evidence related to witness Anne Stoltzfus.
- The District Court found cause and prejudice to excuse the procedural default of the Brady claim and granted the writ, vacating Strickler's conviction and sentence.
- The Commonwealth appealed to the U.S. Court of Appeals for the Fourth Circuit, which reversed the District Court, holding that the Brady claim was procedurally defaulted and lacked merit.
- The United States Supreme Court granted certiorari to review the Fourth Circuit's decision.
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Issue:
Does the prosecution's suppression of exculpatory impeachment evidence violate the Due Process Clause under Brady v. Maryland where the defendant cannot demonstrate a reasonable probability that disclosing the evidence would have produced a different outcome in either the guilt or sentencing phase of his capital murder trial?
Opinions:
Majority - Justice Stevens
No. Although the prosecution suppressed favorable impeachment evidence concerning eyewitness Anne Stoltzfus, this suppression did not result in a constitutional violation because the evidence was not material. There are three components of a true Brady violation: (1) the evidence must be favorable to the accused, either because it is exculpatory or impeaching; (2) the evidence must have been suppressed by the State; and (3) prejudice must have ensued. While Strickler established the first two components and demonstrated cause for his procedural default, he failed to establish prejudice. The materiality standard requires a 'reasonable probability' that the result of the proceeding would have been different, which means a probability sufficient to undermine confidence in the outcome. Even if Stoltzfus’s testimony were completely discredited, there was substantial other evidence—including forensic evidence, testimony from other witnesses placing Strickler with the victim's car near the scene, and his possession of the victim's property—sufficient to support the capital murder conviction and death sentence. Therefore, confidence in the verdict is not undermined.
Concurring-in-part-and-dissenting-in-part - Justice Souter
Yes, with respect to the sentencing phase. The failure to disclose the Stoltzfus materials violated the Due Process Clause because there is a reasonable probability, or a 'significant possibility,' that it would have led the jury to recommend a life sentence instead of death. I agree with the majority that Strickler has shown cause for his procedural default and that the conviction for capital murder should stand. However, the majority underestimates the impact of Stoltzfus's testimony on the jury's sentencing decision. Her testimony was the primary evidence painting Strickler as the aggressive, dominant ringleader—the 'Mountain Man'—while his accomplice was the passive 'Shy Guy.' This narrative of dominance was critical to the jury's discretionary sentencing choice. Had the defense been able to destroy Stoltzfus's credibility with the suppressed documents, it is reasonably probable that at least one juror would have refused to recommend the death penalty, thereby changing the outcome.
Analysis:
This case clarifies the interaction between the Brady rule and the cause-and-prejudice standard for overcoming procedural default in federal habeas corpus proceedings. It establishes that the state's suppression of exculpatory evidence can itself constitute 'cause' for a petitioner's failure to raise the claim in state court. The decision also merges the prejudice inquiry for the procedural default with the materiality prong of the underlying Brady claim, holding that they are identical standards. Ultimately, the ruling reinforces the high bar for proving Brady materiality, demonstrating that even the suppression of 'devastating' impeachment evidence against a key eyewitness may not be enough to undermine confidence in a verdict supported by other strong, independent evidence.
