LUIS CARLOS ARANGO, A/K/A CARLOS LUIS ARANGO, APPELLANT,
v.
THE STATE OF FLORIDA, APPELLEE
AI-generated. These summaries, headnotes, and key points are machine-generated and may contain errors or omissions. Always verify against the full opinion text below. Not legal advice.
Luis Arango was convicted of first-degree murder and sentenced to death. The U.S. Supreme Court vacated and remanded the Florida Supreme Court's prior decision for reconsideration under the materiality standard established in United States v. Bagley. The Florida Supreme Court reaffirmed its prior holding that suppressed exculpatory evidence regarding a pistol found near Arango's apartment constituted a Brady violation and warranted a new trial.
The suppressed evidence was material under the Bagley standard because there is a reasonable probability that had the evidence been disclosed to the defense, the result of the proceeding would have been different. Due process required a new trial given the suppressed exculpatory evidence coupled with the prosecutor's argument that nothing was kept from the jury and that Arango's testimony did not support a reasonable doubt.
[1] Suppression of exculpatory evidence favorable to the defense, particularly after a specific request for disclosure, may constitute a Brady violation.
[2] Exculpatory evidence is material if there is a reasonable probability that its disclosure to the defense would have altered the outcome of the proceeding.
Previewing 2 of 5 headnotes on this case. FLexlaw’s editorially structured points of law — every proposition, pinpointed — are reserved for members.
Join FLexlaw to unlock all legal intelligence“evidence is material only if there is a reasonable probability that, had the evidence been disclosed to the defense, the result of the proceeding would have been different.”
Establishes the Bagley materiality standard that the court applied to evaluate the suppressed evidence
Previewing 1 of 3 key quotes on this case — the court’s exact language, pinpointed for members.
Join FLexlaw to unlock all legal intelligenceArango was convicted of first-degree murder and sentenced to death. After trial and direct appeal, Arango discovered that a pistol had been found unde…
The full statement of facts, procedural history, and disposition for this case are member content.
Join FLexlaw to unlock all legal intelligence© FLexlaw, Inc. — AI-generated enrichments are proprietary. All rights reserved.
Explore caselaw by topic → Browse Suppression Of Exculpatory Evidence cases and more on FLexlaw
PER CURIAM.
The United States Supreme Court has entered an order * vacating Arango v. State, 467 So. 2d 692 (Fla.1985), and remanding it for further consideration in light of United States v. Bagley, 473 U.S. 667, 105 S.Ct. 3375, 87 L.Ed.2d 481 (1985). We have jurisdiction, article V, section 3(b)(1), Florida Constitution.
Arango was convicted of first-degree murder and sentenced to death. We affirmed on direct appeal. Arango v. State, 411 So. 2d 172 (Fla.), cert. denied, 457 U.S. 1140, 102 S.Ct. 2973, 73 L.Ed.2d 1360 (1982). Arango sought post-conviction relief, arguing that he discovered, after trial and direct appeal, that a pistol had been found under the balcony of his apartment and turned over to the police; that the pistol was exculpatory evidence supportive of his defense that three armed Latin males overpowered him and the victim and then escaped, one jumping off the bedroom balcony. We reversed the trial court’s denial of relief, finding that Arango had stated a prima facie case of a discovery violation under Brady v. Maryland, 373 U.S. 83, 83 S.Ct. 11, 4, 10 L.Ed.2d 215 (1963), and remanded to the trial court for a hearing on the claimed Brady violation. Aran-go v. State, 437 So. 2d 1099 (Fla.1983).
The trial court again denied relief. This Court reversed the trial court’s denial, vacated the death sentence, and remanded to the trial court for a new trial. We found that the state had suppressed evidence favorable to the defense following a specific defense request for disclosure, that the suppressed exculpatory evidence was mate rial in that it might have affected the outcome of the trial, see United States v. Agurs, 427 U.S. 97, 96 S.Ct. 2392, 49 L.Ed.2d 342 (1976), and that, in fact, Aran-go was deprived of a fair trial. “The prosecutor was able to argue to the jury that ‘nothing was kept from you, whatever we had is on the table/ that Arango’s testimony was ‘not real because it does not jive [sic] with the physical evidence’ and, therefore, ‘does not create a reasonable doubt.’ ” Arango, 467 So. 2d at 694. We found that due process required a new trial under the circumstances — suppressed exculpatory evidence coupled with the foregoing prosecutorial argument to the jury.
In Bag ley the Court held that “evidence is material only if there is a reasonable probability that, had the evidence been disclosed to the defense, the result of the proceeding would have been different. Id. 105 S.Ct. at 3384 (Blackmun, J.), 105 S.Ct. at 3385 (White, J., concurring in part and concurring in judgment). “A ‘reasonable probability’ is a probability sufficient to undermine confidence in the outcome.” Id. 105 S.Ct. at 3384.
Applying the Bagley test of materiality, we are satisfied that we reached a correct conclusion in Arango v. State, 467 So. 2d 692 (Fla.1985). Our review of the record convinces us that there is a reasonable probability that had the suppressed evidence been disclosed to the defense, the results of the proceedings would have been different. Having reconsidered the case in light of the United States Supreme Court mandate, we remand to the trial court for a new trial.
It is so ordered.
McDonald, C.J„ and ADKINS, BOYD, OVERTON, SHAW and BARKETT, JJ., concur. EHRLICH, J., dissents.
*
— U.S.-, 106 S.Ct. 41, 88 L.Ed.2d 34 (1985).
Cases With Similar Vibessemantic neighbors from the corpus
Citator
Cited By
-
Lewis v. State, 497 So. 2d 1162 (Fla. 3d DCA 1986)…no showing of a reasonable probability that, had the evidence been disclosed, the result of the proceeding would have been different. United States v. Bagley, 473 U.S. 667, 105 S.Ct. 3375, 3384-85, 87 L.Ed.2d 481, 494-95 (1985). Cf Arango v. State, 497 So. 2d 1161 (Fla.1986) (court found a reasonable probability that results of the proceedings would have been different had suppressed evidence been disclosed). Affirmed. BASKIN and FERGUSON, JJ., concur.…
-
Boshears v. State, 511 So. 2d 721 (Fla. 1st DCA 1987)…the defense, the result of the proceeding would have been different. A “reasonable probability” is a probability sufficient to undermine confidence in the outcome. Bagley, 473 U.S. at 682, 105 S.Ct. at 3384, 87 L.Ed.2d at 494. In Arango v. State, 497 So. 2d 1161 (Fla.1986), the defendant sought post-conviction relief, alleging as has appellant herein, that he discovered after trial and after appeal that the police were in possession of exculpatory evidence supportive of his defense. The supreme court found…
-
Perri v. State, 569 So. 2d 1348 (Fla. 3d DCA 1990)…se it cannot be said that the result of Perri’s trial probably would have been different if the impeachment evidence regarding Weiss’s pending motion to mitigate a negotiated sentence had been disclosed. United States v. Bagley. Cf. Arango v. State, 497 So. 2d 1161 (Fla.1986) (where the court, using a Brady/Bagley analysis, held that reasonable probability existed that had a pistol found at the murder scene been disclosed to the defense, the results of the murder prosecution would have been different). Affirm…
Previewing 3 of 4 citing cases — full citator treatment, depth of discussion, and citing context are member features.
Join FLexlaw to unlock all legal intelligenceAuthorities Cited
- Brady v. Maryland, 373 U.S. 83 (U.S. 1963)
- United States v. Agurs, 427 U.S. 97 (U.S. 1976)
- United States v. Bagley, 473 U.S. 667 (U.S. 1985)
- Arango v. State, 411 So. 2d 172 (Fla. 1982)
- United States v. Haley, 371 U.S. 18 (U.S. 1962)
- Arango v. State, 437 So. 2d 1099 (Fla. 1983)
- Consolidated Motor Inns v. BVA Credit Corp., 457 U.S. 1140 (U.S. 1982)
- Pope v. Thone, 457 U.S. 1140 (U.S. 1982)
- Arango v. State, 467 So. 2d 692 (Fla. 1985)