State ex rel. Reginald Clemons v. Steve Larkins, Superintendent

Summary

The Supreme Court of Missouri, sitting en banc, reviewed Reginald Clemons’s habeas corpus petition challenging his convictions and death sentences for the murders of Julie Kerry and Robin Kerry. The Court adopted the special master’s finding that the state violated Brady v. Maryland by withholding material evidence concerning an injury to Clemons’s face and an altered police report. Concluding that the violation undermined confidence in the verdicts, the Court vacated Clemons’s convictions and sentences and authorized the state to elect whether to retry him.

Holdings

1. The master's factual findings and legal conclusions must be sustained unless unsupported by substantial evidence, against the weight of the evidence, or based on an erroneous declaration or application of law; substantial deference is owed to the master's credibility determinations.
2. Deliberate concealment by the State of material evidence that was not reasonably available to the defense constitutes cause sufficient to overcome the procedural bar to habeas review.
3. Evidence from an independent, objective witness corroborating a defendant's claim that police coerced a confession and impeaching a State witness's contrary testimony is favorable evidence under Brady.
4. The State violated Brady by suppressing the Weeks evidence, and the suppression was material because there was a reasonable probability of a different result in the suppression hearing or trial, undermining confidence in the convictions and sentences.
5. Clemons was entitled to habeas relief, and the Court vacated his convictions and death sentences for first-degree murder.

Questions Presented

1. Whether the State's suppression and alteration of evidence concerning Warren Weeks's observation of Clemons's facial injury violated Brady v. Maryland.
2. Whether the suppressed evidence was favorable, suppressed by the State, and material so as to prejudice Clemons and overcome the procedural bar through cause and prejudice.
3. Whether Clemons was entitled to habeas relief requiring vacation of his convictions and death sentences.
4. Whether Clemons's proportionality challenge to his death sentences required consideration.

Disposition

vacated