State v. Anderson

Summary

The Louisiana Supreme Court held that the Fourth Circuit erred in ordering a pretrial evidentiary hearing on whether a witness's alleged request for money in exchange for testimony was discoverable under Brady v. Maryland. The court vacated the order and remanded, emphasizing that Brady materiality requires a showing sufficient to undermine confidence in the eventual verdict and that the prosecutor retains discretion during the pretrial stage.

Holdings

1. A trial court must hold a contradictory hearing to resolve a dispute over the scope of pretrial discovery unless it appears on the face of the motion that the moving party is not entitled to relief as a matter of law.
2. Brady does not establish a general rule of criminal discovery, and the Constitution is not violated by every failure or refusal by the government to disclose evidence that might help the defense.
3. The Fourth Circuit's order directing the limited evidentiary hearing was vacated, and the case was remanded to the trial court for further proceedings consistent with the Louisiana Supreme Court's views.

Questions Presented

1. Whether the Fourth Circuit properly ordered an evidentiary hearing limited to whether evidence that a state witness sought payment for testimony was discoverable under Brady.
2. Whether Louisiana Code of Criminal Procedure article 729.1(A) requires a contradictory hearing to resolve a dispute over the scope of pretrial discovery unless the moving party is facially not entitled to relief.
3. Whether Brady establishes a general rule requiring disclosure of every potentially favorable item during the pretrial stage, without a further showing of materiality.

Disposition

vacated