Dennis v. Sec'y PA Dept. of Corrs., No. 13-9003 (3d Cir. 2016)
Annotate this CaseAfter a jury trial, Defendant was found guilty of first-degree murder. The jury sentenced Defendant to death. The Pennsylvania Supreme Court affirmed the convictions on appeal, rejecting Defendant’s claims that the prosecution violated Brady v. Maryland. The Supreme Court denied Defendant’s application for postconviction relief. Defendant then filed an application under 28 U.S.C. 2254. The district court granted Defendant a conditional writ of habeas corpus and directed the Commonwealth to retry Defendant or release him, concluding that the prosecution had breached its obligations under Brady by withholding three pieces of exculpatory and material information. The Third Circuit initially vacated the district court’s order, but subsequently, acting en banc, affirmed. The suppressed Brady material—a receipt corroborating Dennis’s alibi, an inconsistent statement by the Commonwealth’s key eyewitness, and documents indicating that another individual committed the murder — effectively gutted the Commonwealth’s case against Dennis. The withholding of these pieces of evidence denied Dennis a fair trial in state court.
This opinion or order relates to an opinion or order originally issued on February 9, 2015.
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