Summary
The Montana Supreme Court affirmed Richard Douglas Reinert’s deliberate-homicide conviction and the denial of his motion for a new trial. The court held that the State’s alleged withholding of impeachment evidence concerning the forensic pathologist did not establish a material Brady violation. It also held that the District Court properly allowed cross-examination about a prior police report to rebut Reinert’s evidence of peacefulness and truthfulness in support of his self-defense theory.
Topics
Practice areas
Questions Presented
- Whether the District Court erred in denying Reinert's motion for a new trial based on the State's alleged suppression of exculpatory or impeachment evidence concerning forensic pathologist Dr. Thomas Bennett.
- Whether the District Court abused its discretion by allowing the State to cross-examine Reinert about a prior bad act to rebut his evidence that he was peaceful and truthful and his claim of justified use of deadly force.
Holdings
- Reinert failed to establish a Brady violation because the alleged impeachment evidence did not create a reasonable probability that disclosure would have changed the outcome of the trial. The District Court therefore did not abuse its discretion in denying the motion for a new trial.
- The District Court did not abuse its discretion by allowing limited cross-examination about Reinert's prior police report because Reinert had introduced evidence of his peacefulness and truthfulness, thereby opening the door to legitimate rebuttal concerning character for truthfulness.
Key quotations
“To prove a reasonable probability that the result would have been different, a defendant need only show that "the likelihood of a different result is great enough to undermine confidence in the outcome of the trial."” (419 P.3d at 666)
Factual background
Reinert shot and killed Jessica Stephenson inside his home after an evening involving substantial alcohol consumption and a domestic dispute involving Reinert, his wife Danielle, and Stephenson. Reinert admitted shooting Stephenson but claimed he acted in self-defense because he believed she was approaching him with an object and that he was in danger of serious bodily injury or death. At trial, the State presented the 911 recording, physical evidence, forensic testimony, and evidence concerning Reinert's statements and conduct. After Reinert presented evidence that he was peaceful and trustworthy, the State cross-examined him about a prior police report that he later acknowledged was unfounded.
Procedural history
A jury found Reinert guilty of deliberate homicide and use of a deadly weapon after a five-day trial. He moved for a new trial, alleging that the State withheld favorable impeachment evidence concerning its forensic pathologist and that the State had improperly introduced a prior bad act. The District Court denied the motion, and the Montana Supreme Court affirmed.