Summary
This Supreme Court opinion addresses whether the prosecution violated its constitutional obligation to correct false testimony under Napue v. Illinois during Richard Glossip’s capital murder trial. Following an independent investigation and the disclosure of previously withheld documents, Oklahoma’s attorney general conceded that prosecutors knowingly allowed the key witness, Justin Sneed, to falsely testify about his psychiatric medication. The Court held that this failure, combined with other prosecutorial misconduct, deprived Glossip of due process and warranted a new trial, reversing the Oklahoma Court of Criminal Appeals’ denial of post-conviction relief.
Topics
Practice areas
Questions Presented
- Whether the prosecution’s failure to correct Sneed’s false testimony violated Napue v. Illinois.
- Whether the Oklahoma Post‑Conviction Procedures Act provides an independent and adequate state ground precluding Supreme Court review.
- Whether Glossip is entitled to a new trial.
Holdings
- The prosecution violated its constitutional obligation to correct false testimony; a new trial is warranted.
- The OCCA’s reliance on the PCPA is not an independent ground because it depended on a federal Napue determination; therefore the Supreme Court has jurisdiction.
- Glossip’s conviction is vacated and the case is remanded for a new trial.
Key quotations
“The prosecution’s failure to correct Sneed’s false testimony violated the Fourteenth Amendment’s Due Process Clause.” (at 16)
“The OCCA’s application of the PCPA is not an independent ground because it depended on the federal Napue determination.” (at 14)
Factual background
In 1997 Justin Sneed murdered Barry Van Treese at an Oklahoma hotel managed by Richard Glossip. Sneed testified that Glossip directed the killing, and his testimony was the sole direct evidence linking Glossip to the crime. After the trial, Sneed falsely testified that he had never been prescribed lithium, although medical records later showed he was taking lithium for bipolar disorder. The prosecution failed to correct this false testimony.
Procedural history
The Oklahoma Court of Criminal Appeals reversed Glossip's first conviction, affirmed his second conviction, and subsequently denied his successive post‑conviction relief petitions on procedural and merit grounds. The State later conceded a Napue error, but the OCCA held the confession was not "based in law or fact" and applied the Oklahoma Post‑Conviction Procedures Act to bar relief. The Supreme Court granted certiorari and reviewed the federal constitutional claims.
Remand instructions
Remand to the Oklahoma Court of Criminal Appeals for a new trial consistent with the Napue violation finding.