State v. Harris

Summary

The Supreme Court of Wisconsin held that due process does not require disclosure of material impeachment evidence before a defendant enters a plea bargain, under United States v. Ruiz. It nevertheless held that the State violated Wisconsin's reciprocal discovery statute by failing to disclose evidence that the alleged victim had reported a sexual assault by her grandfather. Because the nondisclosure affected Harris's decision to plead guilty, the court affirmed the withdrawal of his guilty plea as necessary to avoid a manifest injustice.

Holdings

1. Due process does not require the disclosure of material exculpatory impeachment information before a criminal defendant enters into a plea bargain.
2. Under Wis. Stat. § 971.23(1)(h), the State was required to disclose the alleged victim's prior allegation against her grandfather because it was favorable exculpatory impeachment evidence whose nondisclosure undermined confidence in the judicial proceeding.
3. For purposes of Wis. Stat. § 971.23(1), evidence must be disclosed within sufficient time before trial for the defendant to make effective use of it.
4. A defendant may withdraw a guilty plea to avoid manifest injustice when a statutory discovery violation deprives the defendant of material exculpatory impeachment evidence and induces the guilty plea.

Questions Presented

1. Whether due process required the State to disclose material exculpatory impeachment information before Harris entered into a plea bargain.
2. Whether the State violated Wis. Stat. § 971.23(1)(h) by failing to disclose the alleged victim's prior sexual-assault allegation as exculpatory evidence.
3. Whether the statutory nondisclosure entitled Harris to withdraw his guilty plea to avoid a manifest injustice.

Disposition

affirmed