JAMES SMITH, APPELLANT,
v.
THE STATE OF FLORIDA, APPELLEE
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James Smith was convicted of grand larceny and appealed on Brady v. Maryland grounds, claiming the State withheld material evidence that could have created reasonable doubt. The Florida District Court of Appeal affirmed the conviction, finding that under United States v. Agurs, any omitted evidence was not sufficiently material to affect the trial's outcome.
The conviction is affirmed. Under United States v. Agurs, a conviction will not be reversed for Brady violation unless the omission is of sufficient importance to result in denial of the defendant's right to a fair trial. Here, the proof of guilt was beyond reasonable doubt and the omitted evidence could have had no meaningful effect on the outcome.
[1] A conviction will not be reversed for a Brady violation unless the omission is of sufficient importance to result in a denial of the defendant's right to a fair trial.
[2] The mere possibility that an item of undisclosed information might have helped the defense does not establish materiality in the constitutional sense.
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Join FLexlaw to unlock all legal intelligence“a conviction will not be reversed for violation of the Brady rule unless the omission is of sufficient importance to result in a denial of defendant's right to a fair trial”
Establishes the materiality standard from United States v. Agurs that applies to Brady violations
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Join FLexlaw to unlock all legal intelligenceSmith was found guilty of grand larceny. The State allegedly possessed material that might have given rise to reasonable doubt concerning Smith's guil…
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PER CURIAM.
The defendant, who is appellant here, was found guilty of grand larceny. On this appeal, reversal is claimed upon the ground that the State had in its possession material which might have given rise to a reasonable doubt concerning appellant’s guilt and that the State failed to furnish this material. See Brady v. Maryland, 373 U.S. 83, 83 S.Ct. 1194, 10 L.Ed.2d 215 (1963); and Beasley v. State, 315 So. 2d 540 (Fla.2d DCA 1975).
Our review of the record convinces us that the limitation upon Brady imposed by the United States Supreme Court in United States v. Agurs, 427 U.S. 97, 96 S.Ct. 2392, 49 L.Ed.2d 342 (1976), applies. In that case, the Supreme Court held that a conviction will not be reversed for violation of the Brady rule unless the omission is of sufficient importance to result in a denial of defendant’s right to a fair trial.1 It is clear from this record that the proof of the present defendant’s guilt was beyond a reasonable doubt and that the omission claimed could have had no meaningful effect upon the outcome of the trial. Cf. Cravero v. State, 349 So. 2d 649 (Fla. 3d DCA 1977). Therefore, we find no error. Accordingly, the judgment is affirmed.
. “While expressing the opinion that representatives of the State may not ‘suppress substantial material evidence,’ former Chief Justice Traynor of the California Supreme Court has pointed out that ‘they are under no duty to report sua sponte to the defendant all that they learn about the case and about their witnesses.’ In re Imbler, 60 Cal.2d 554, 569, 35 Cal.Rptr. 293, 301, 387 P. 2d 6, 14 (1963). And this Court recently noted that there is ‘no constitutional requirement that the prosecution make a complete and detailed accounting to the defense of all police investigatory work on a case.’ Moore v. Illinois, 408 U.S. 786, 795, 92 S.Ct. 2562, 33 L.Ed.2d 706. The mere possibility that an item of undisclosed information might have helped the defense, or might have affected the outcome of the trial, does not establish ‘materiality’ in the constitutional sense.” United States v. Agurs, 427 U.S. at 109-110, 96 S.Ct. at 2400.
Cases With Similar Vibessemantic neighbors from the corpus
Citator
Authorities Cited
- Brady v. Maryland, 373 U.S. 83 (U.S. 1963)
- United States v. Agurs, 427 U.S. 97 (U.S. 1976)
- Moore v. Illinois, 408 U.S. 786 (U.S. 1972)
- Cravero v. State, 349 So. 2d 649 (Fla. 3d DCA 1977)
- Beasley v. State, 315 So. 2d 540 (Fla. 2d DCA 1975)