Danforth, Warden v. Chapman

Summary

The Georgia Supreme Court affirmed the grant of habeas corpus relief to Justin W. Chapman, who had been convicted of arson and felony murder. The court held that the State’s suppression of impeachment and exculpatory evidence concerning its principal witness violated Brady and Giglio, making a new trial appropriate, and dismissed Chapman’s cross-appeal as moot.

Holdings

1. The Warden failed to identify authority requiring the habeas court to permit post-hearing briefs, so the claim of error was without merit.
2. The undisclosed videotape, William Liner's statements, and the missing page from Joseph White's letter constituted favorable evidence that could have been used to impeach White and created a reasonable probability of a different trial outcome; therefore, the habeas court properly granted relief under Brady and Giglio.
3. The Warden's remaining allegations of error were moot because Chapman was entitled to a new trial, and Chapman's cross-appeal was dismissed as moot after the grant of habeas relief was affirmed.

Questions Presented

1. Whether the habeas court erred by denying the Warden's request to file a post-hearing brief.
2. Whether the prosecution's failure to disclose impeachment and other favorable evidence concerning the State's primary confession witness violated Brady v. Maryland and Giglio v. United States and entitled Chapman to a new trial.
3. Whether Chapman's cross-appeal presented any live issue after the grant of habeas relief was affirmed.

Disposition

affirmed