Browning v. Trammell, No. 11-5102 (10th Cir. 2013)
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Defendant Michael Allen Browning was convicted by jury for the murder of Harry and Teresa Hye, the parents of his girlfriend Cenessa Tackett. Browning received a death sentence as punishment for these crimes. The Oklahoma Court of Criminal Appeals affirmed this conviction and sentence on direct appeal and denied post-conviction relief. What the jury (and defense attorneys) did not know was that Tackett, who became the most important witness at trial, had been diagnosed with a severe mental disorder. According to records from her psychiatrist that were in the State's possession, Tackett blurred reality and fantasy, suffered from memory deficits, tended to project blame onto others, and had an assaultive, combative, and even potentially homicidal disposition. In subsequent proceedings, the contents of Tackett's mental health records came to light, prompting the federal district court to grant a conditional writ of habeas corpus. The court reasoned that Tackett's mental health records were favorable to Browning and material to his defense, especially considering Browning's trial strategy to paint Tackett herself as complicit in the murders. The district court therefore ruled that the Constitution obligated the State to disclose those records to Browning before trial. Given the central role Tackett played at trial and the severity of her mental health diagnosis, the Tenth Circuit agreed with the district court that the psychiatric information was favorable to Browning and material to his defense, and that the Oklahoma courts could not have reasonably concluded otherwise.
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