Monroe v. Blackburn, Warden

Background

A man convicted and sentenced to death for the 1978 murder of his neighbor was retried after an earlier reversal. The State’s case rested largely on identifications by the victim’s two children, then ages 12 and 11. Months after the conviction, a Michigan detective told New Orleans police that a different man had confessed to a similar killing and said the same thing happened to his former wife, the victim. Those police notes were not disclosed to the defense while the conviction and state appeals were pending.

Reasoning

Federal courts later found the undisclosed information to be favorable and material under the Court’s rules barring suppression of exculpatory evidence. A federal district court held that the information could create reasonable doubt and granted relief, but it did not order immediate release or a new trial. Instead, the court directed Louisiana to allow the prisoner to pursue state post-conviction relief based on the newly disclosed evidence within state time limits. The Court of Appeals upheld that remedy. The Supreme Court denied review of the case.

Real world impact

The denial leaves in place the lower courts’ approach requiring state post-conviction procedures rather than immediate retrial or release. Police failure to disclose the notes remained central to the dispute. Because the Supreme Court denied review, the case does not resolve whether the constitutional rule requires a different remedy when suppressed evidence prevented timely state proceedings.

Dissents or concurrances

Justice Marshall, joined by Justice Brennan, dissented from the denial. He would have granted review and argued the proper remedy after a Brady violation is release or retrial, not merely a return to state procedures.