Harris v. State, 407 Md. 503

Summary

The Maryland Court of Appeals considered whether the State violated Brady v. Maryland by failing to disclose impeachment evidence concerning plea agreements and sentencing benefits offered to two principal prosecution witnesses. The court held that the undisclosed information was Brady material and that its nondisclosure was material because the case substantially turned on the credibility of the witnesses. The court reversed the intermediate appellate court's decision affirming the denial of post-conviction relief.

Holdings

1. The State's commitments not to oppose, and potentially to support, further sentence reductions for Brill and Bartee in connection with their testimony constituted favorable impeachment evidence that the State was constitutionally required to disclose.
2. The nondisclosure was material because there was a reasonable probability that disclosure of the contingent sentence-reduction commitments would have caused the jury to assess Brill's and Bartee's credibility differently and would have undermined confidence in the verdict.
3. Harris was entitled to post-conviction relief and a new trial.

Questions Presented

1. Whether the State's commitments not to oppose, and potentially to support, further sentence reductions for Brill and Bartee constituted favorable impeachment evidence subject to disclosure under Brady v. Maryland.
2. Whether the State's suppression of those commitments was material under the applicable Brady materiality standard.
3. Whether Harris was entitled to post-conviction relief and a new trial.

Disposition

reversed_and_remanded