Summary
Anthony DeCiantis appealed the denial of his application for postconviction relief following his first-degree murder conviction. He alleged that the prosecution withheld exculpatory and impeachment evidence concerning witness William Ferle, including Ferle’s criminal activity and benefits received while cooperating with the state. The Supreme Court of Rhode Island affirmed the Superior Court’s judgment, concluding that the asserted nondisclosures did not warrant relief.
Holdings
- A deliberate nondisclosure of favorable evidence constitutes grounds for a new trial regardless of the degree of harm to the defendant; when nondisclosure is not deliberate, the applicant must establish materiality by showing a reasonable probability that disclosure would have changed the proceeding's result.
- The prosecution's disclosure obligations extend to uncharged alleged crimes of a witness when those acts may be favorable impeachment evidence, even though Rule 16 expressly refers to records of prior convictions.
- DeCiantis failed to establish that the undisclosed additional criminal activity, expenditures, or arrangements involving Ferle were material because there was no reasonable probability that disclosure would have changed the result.
- The hearing justice did not clearly err in crediting prosecutor Leach's testimony, finding no deliberate nondisclosure, and concluding that no prosecutorial misconduct occurred.
Questions Presented
- Whether the prosecution deliberately withheld exculpatory or impeachment evidence concerning witness William Ferle in violation of due process and discovery obligations.
- Whether the prosecution was required to disclose Ferle's uncharged criminal acts that could have been used to impeach him.
- Whether the hearing justice applied an improper materiality standard to alleged deliberate nondisclosure.
- Whether the hearing justice clearly erred in finding that no prosecutorial misconduct occurred and that the undisclosed evidence was not material.
Disposition
affirmed
Cases Cited (17)
- State v. DeCiantis, 501 A.2d 365 (R.I. 1985)(followed)
- DeCiantis v. State, 666 A.2d 410 (R.I. 1995)(cited)
- DeCiantis v. State, 599 A.2d 734 (R.I. 1991)(cited)
- Page v. State, 995 A.2d 934, 942 (R.I. 2010)(followed)
- Mattatall v. State, 947 A.2d 896, 901 (R.I. 2008)(followed)
- Washington v. State, 989 A.2d 94, 98 (R.I. 2010)(followed)
- Ouimette v. State, 785 A.2d 1132, 1135 (R.I. 2001)(followed)
- State v. Briggs, 886 A.2d 735, 754-55 (R.I. 2005)(followed)
- State v. Langstaff, 994 A.2d 1216, 1219 (R.I. 2010)(cited)
- State v. Chalk, 816 A.2d 413, 418-19 (R.I. 2002)(followed)
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