State ex rel. Reginald Griffin v. Larry Denney

Summary

The Supreme Court of Missouri granted Reginald Griffin habeas corpus relief, holding that the State violated Brady v. Maryland by failing to disclose that inmate Jeffrey Smith possessed a sharpened screwdriver shortly after the murder. Considering that evidence together with post-trial developments, including witness recantations and alternate-perpetrator testimony, the majority concluded that Griffin’s conviction was no longer worthy of confidence. The conviction was vacated, and the State was ordered either to retry Griffin or discharge him from custody.

Holdings

1. Evidence that inmate Smith possessed a sharpened screwdriver shortly after the murder was favorable to Griffin because it tended to support an alternative-perpetrator defense and further impeach the State's principal witnesses.
2. The State suppressed the evidence concerning Smith's possession of the sharpened screwdriver, and the State's disclosure duty extended to material evidence known to prison guards acting on the government's behalf.
3. Griffin established prejudice because the nondisclosure, considered with the totality of the evidence and subsequent developments, rendered the conviction no longer worthy of confidence; the State's nondisclosure also supplied cause for the procedural default.
4. The murder conviction was vacated, and Griffin was ordered discharged from custody unless the State elected to retry him within 60 days after the mandate issued.

Questions Presented

1. Whether the State's failure to disclose evidence that inmate Jeffrey Smith possessed a sharpened screwdriver shortly after the murder violated Brady v. Maryland.
2. Whether the undisclosed evidence established cause and prejudice sufficient to overcome the procedural bar applicable to Griffin's habeas claim.
3. Whether the totality of the undisclosed evidence and subsequent developments rendered Griffin's murder conviction no longer worthy of confidence.

Disposition

vacated