Michigan v. Chenault (Opinion - Leave Granted)
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The issue this case presented for the Michigan Supreme Court centered on the proper test for applying the United States Supreme Court’s decision in Brady v Maryland. In "Michigan v. Lester," (591 NW 2d 267 (1998)), the Court of Appeals adopted a four-factor test that added a requirement of defendant diligence to the traditional Brady test. Neither the Supreme Court of the United States nor the Michigan Supreme Court endorsed that element. Defendant’s convictions for felony murder, and possession of a firearm during the commission of a felony arose out of the shooting death of Kevin Harris in 2008. Harris was a cocaine dealer, who often used Jared Chambers as a middleman to connect with buyers. Chambers occasionally contacted Harris through Harris’ girlfriend, Heather Holloway. The sole question at trial concerned the identity of the shooter. Only defendant, Holloway, and Chambers witnessed the shooting and they did not agree about what happened: defendant identified Chambers as the shooter while Holloway and Chambers identified defendant. There was no physical evidence to tie either defendant or Chambers to the shooting. The defense theory was that Chambers shot Harris, and that Holloway identified defendant as the shooter out of fear of Chambers. On the last day of trial, the prosecution called its final witness. When questioned, that witness was surprised that Holloway’s second written statement did not confirm that she had mentioned Chambers and was confident that the video recordings would verify his recollection. He was also surprised to learn that the recordings had not been provided to defendant. After trial, defense counsel filed a motion for a new trial and requested a copy of the interview recordings. Counsel amended the motion to add claims of ineffective assistance of counsel and prosecutorial misconduct regarding the failure to provide the recorded statements. There was no dispute that the defendant never had the recordings. The trial court granted the defendant’s motion for a new trial, concluding that his due process rights were violated pursuant to Brady because the suppressed videotaped recordings undermined confidence in the outcome of the trial. The Court of Appeals reversed the trial court. The Supreme Court held that a diligence requirement was not supported by Brady or its progeny. Thus, the Court overruled Lester and reaffirmed the traditional three-factor Brady test. Because defendant could not establish that the suppressed evidence was material, however, his Brady claim failed.
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