Case Brief

Robert Munoz

CJAD 405

Professor D’Alesio

23 January 2015

Maddox v. Montgomery

United States Court of Appeals,

Eleventh Circuit 718 F.2d 1033 (11th Cir. 1983)

Facts:

Maddox was indicted and convicted for rape in a Georgia state court and has been sentenced to life imprisonment. Maddox unsuccessfully appealed this decision. He then filed habeas corpus petition, alleging prosecutorial suppression of exculpatory evidence in violation of the doctrine of Brady v. Maryland. The following are the types of situations in which the Brady Doctrine apples:

1) The prosecutor has not disclosed information despite a specific defense request.

2) The prosecutor has not disclosed information despite a general defense request for all exculpatory information or without any defense request at all.

3) The prosecutor knows or should know that the conviction is based on false evidence.

4) The prosecutor fails to disclose purely impeaching evidence not concerning a substantive issue, in the absence of a specific defense request.

Proof is also required to show that the accused actually believed that some particular official proceeding was likely to occur in the near future and was incorrectly informed that said “official proceeding” includes and investigation, according to United States v. Anderson.

Issue:

Maddox argued that his right to due process has been violated as outlined and in violation of the doctrine of Brady v. Maryland. The argument was made that the state failed to disclose any information from the police investigation, more specifically, photographs of the bedspread being made shortly after the alleged rape. Maddox had also appealed the denial of habeas relief.

Decision of the Court:

The United States Court of Appeals ruled that the suppressed evidence is “purely impeaching evidence and no defense request has been made, the suppressed evidence is material only if its introduction probably would have resulted in an acquittal.” Given a...