State of Maine v. John D. Williams

Summary

The Maine Supreme Judicial Court affirmed the denial of John D. Williams’s motion for a new trial based on allegedly suppressed disciplinary evidence concerning a Maine State Trooper involved in his arrest. The court held that Williams failed to establish that the disciplinary report was favorable impeachment evidence or that its nondisclosure caused prejudice under Brady and Giglio. The court concluded that the trial court did not abuse its discretion.

Holdings

1. Williams failed to prove by clear and convincing evidence that the disciplinary report was favorable to him because it was exculpatory or impeaching.
2. Williams failed to establish a reasonable probability that disclosure of the disciplinary report would have produced a different verdict.
3. The trial court did not abuse its discretion in denying Williams's motion for a new trial.

Questions Presented

1. Whether the trial court abused its discretion by denying Williams's Rule 33 motion for a new trial based on the alleged suppression of a law-enforcement disciplinary report.
2. Whether the disciplinary report was favorable impeachment evidence and material under Brady and Giglio.
3. Whether Williams proved prejudice, meaning a reasonable probability that disclosure of the report would have produced a different verdict.

Disposition

affirmed