Brown v. State

Summary

The Court affirmed the denial of Brown’s second postconviction motion and motion for a new trial. It held that the exception for new evidence of actual innocence in a successive postconviction motion applies only when the defendant was convicted after a trial, and that a defendant who pleaded guilty cannot obtain a new trial under Rule 33. The Court also held that Brown’s remaining claims were not properly before it because they had not been raised below.