Blake v. State

Summary

The Court of Appeals of Maryland affirmed the denial of post-conviction relief on both ineffective-assistance and due-process claims concerning undisclosed impeachment material about the arresting officer. It held that counsel's decision not to seek the officer's Internal Affairs Division files was reasonable trial strategy and that Blake failed to show prejudice. The Court assumed without deciding that impeachment evidence had to be disclosed before the suppression hearing, but concluded that the evidence was not material because it did not create a reasonable probability of a different result.