Smith v. State

Summary

The court vacated the denial of Smith’s extraordinary motion for a new trial because the trial court applied an incorrect framework to the newly discovered expert evidence. The court held that the trial court improperly evaluated whether the evidence was newly discovered and obtainable through diligence, and improperly decided materiality by choosing which experts were more persuasive rather than assessing how a reasonable juror would have evaluated the new evidence alongside the trial evidence. The case was remanded for reconsideration under the proper framework.