Strickler v. Greene

1999-06-17

Headline: Affirms death-row conviction despite undisclosed eyewitness interview notes, ruling the withheld materials did not create a reasonable probability of a different verdict so the sentence remains in place.

Holding: The Court held that although the Commonwealth failed to disclose an eyewitness’s interview notes and the defendant showed cause for raising the claim late, he failed to prove a reasonable probability the verdict or death sentence would have been different.

Real World Impact:

Requires showing a reasonable probability that withheld evidence would change the outcome.
Confirms prosecutors must disclose police-known favorable evidence to defense.
Allows convictions to stand when other strong evidence supports the verdict.

Topics: eyewitness testimony, police interview notes, prosecutor disclosure, habeas corpus, death penalty cases

Summary

Background

A man convicted of capital murder was sentenced to death after a jury found he and another man abducted, robbed, and killed a college student. An eyewitness, Anne Stoltzfus, gave vivid testimony about the abduction. The District Court later vacated the conviction because prosecutors had not produced Stoltzfus’s earlier interview notes and letters. The Fourth Circuit reversed and the Supreme Court agreed to review whether the withheld materials violated the prosecutor’s duty to disclose.

Reasoning

The Court examined three questions: whether the undisclosed notes were favorable and should have been produced, whether there was an acceptable reason for the defendant’s late claim, and whether the notes were so important that they probably would have changed the outcome. The Court found the notes were impeaching and that suppression and reliance on the prosecutor’s open-file practice established cause. But the Court concluded the defendant failed to show a reasonable probability the verdict or the death sentence would have been different given other eyewitness, forensic, and physical evidence tying him to the crime.

Real world impact

The ruling reiterates that prosecutors must disclose favorable evidence known to police, but nondisclosure does not automatically overturn a conviction. A defendant who shows cause for a late claim still must show a reasonable probability the undisclosed material would have altered the result. The decision leaves the conviction and death sentence intact in this case.

Dissents or concurrances

Justice Souter agreed the materials were impeaching and that cause was shown, but he would have vacated the death sentence, finding a significant possibility the jury’s sentencing recommendation would have changed if Stoltzfus had been impeached.