Supreme Court of the United States
Smith v. Cain
January 10, 2012565 U.S. 73
Summary
The Court held that the State violated Smith’s due-process rights by withholding police notes that materially contradicted the sole eyewitness’s trial identification. Because that eyewitness was the only evidence linking Smith to the murders, the undisclosed statements created a reasonable probability sufficient to undermine confidence in the verdict, requiring reversal and remand. Justice Thomas, dissenting, would have affirmed because the cumulative record substantially corroborated the eyewitness and did not establish materiality.
Holding
- Materiality of the undisclosed eyewitness statements. The undisclosed statements were material because they directly contradicted the eyewitness’s trial identification and there was a reasonable probability that disclosure would have produced a different result or otherwise undermined confidence in the verdict.
Docket 10-8145
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