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LAW 4051 (31)
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Chapter 15

LAW 4051 Chapter 15: Kyles

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LAW 4051

Kyles v. Whitley (1995) Holding (472): "We hold that the prosecutor remains responsible for gauging that effect regardless of any failure by the police to bring favorable evidence to the prosecutor's attention. Because the net effect of the evidence withheld by the State in this case raises a reasonable probability that its disclosure would have produced a different result, Kyles is entitled to a new trial. Facts • Curtis Lee Kyles was charged with the murder of a 60 year old woman, Dolores Dye, in a parking lot, and driving away with her car • two days later, a man named Beanie calls the police and reports that on the day of the murder he bought a red Thunderbird. Beanie subsequently acts as the police's main informant, offering up descriptions, testimony, and ultimately leads them to Curtis Kyles ◦ repeatedly infers that he wants a reward, that he's "not doing this for nothing" (474) ◦ evidence against Kyles = purse in the garbage, a pistol matching the murder weapon, and a receipt from Schwegmann's ◦ exculpatory evidence (476) • Beanie kept changing important elements of the story, and despite the State's strong case, the jury hangs • after initial trial that ended with a hung jury, he was retried, convicted of first degree murder, and sentenced to death Issue: whether the prosecution's affirmative duty to disclose evidence favorable to the defendant created sufficient doubt in the mind of at least one juror to result in a life sentence rather than the death penalty? Four aspects of Bagley: 1."reasonable probability" of a different result: accordingly shown when the gov's evidentiary suppression "undermines confidence in the outcome of a trial" (478) 2.it's not a sufficiency of evidence test: the favorable evidence could
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