Julian Marquez v. Commissioner of Correction

Summary

The court affirmed the judgment because, even assuming the state had failed to disclose a leniency understanding with cooperating witness Edwin Soler and failed to correct his testimony about it, the evidence was immaterial under the applicable due process standard. The court declined to decide whether an agreement actually existed or whether the habeas court abused its discretion in denying certification because the petitioner could not obtain relief regardless. The court also declined to exercise supervisory authority concerning informal cooperation arrangements, while cautioning about their risks. Judge Palmer, concurring, agreed that the evidence was immaterial but would have emphasized that an informal understanding likely existed and should be disclosed or memorialized.