SMITH V. CAIN 132 S.Ct. 627 (2012) CASE BRIEF

SMITH V. CAIN

132 S.Ct. 627 (2012)

NATURE OF THE CASE: Smith (P), inmate, sought post-conviction relief for his first-degree murder conviction. P alleged a Brady violation. The State court rejected the Brady claim, and the Louisiana Court of Appeal and Louisiana Supreme Court denied review. The United States Supreme Court granted certiorari.

FACTS: D charged P with killing five people during an armed robbery. A single witness, linked P to the crime. Boatner testified that he was socializing at a friend's house when P and two other gunmen entered the home, demanded money and drugs, and shortly thereafter began shooting, resulting in the death of five of Boatner's friends. In court Boatner identified P as the first gunman to come through the door. He claimed that he had been face to face with P during the initial moments of the robbery. No other witnesses and no physical evidence implicated P in the crime. P was convicted of 5 counts of first degree murder. The conviction was affirmed. The Louisiana Supreme Court denied review, as did the US Supreme Court. P then sought postconviction relief in state courts. Police notes contain statements by Boatner that conflict with his testimony. The notes from the night of the murder state that Boatner 'could not ... supply a description of the perpetrators other than they were black males.' There was also a handwritten account of a conversation a detective had with Boatner five days after the crime, in which Boatner said he 'could not ID anyone because [he] couldn't see faces' and 'would not know them if [he] saw them.' The typewritten report of that conversation states that Boatner told Ronquillo he 'could not identify any of the perpetrators of the murder' P requested that his conviction be vacated as this was a Brady violation. The state trial court rejected the claim, and the Louisiana Court of Appeal and Louisiana Supreme Court denied review. The Supreme Court granted certiorari.

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