Masten v. United States, No. 12-3495 (8th Cir. 2014)
Annotate this CasePetitioner, convicted of starting a fire that damaged her failing tavern, appealed the district court's denial of a new trial and 28 U.S.C. 2255 relief. The court concluded that there was no Brady violation where the government did not suppress exculpatory evidence shown on an original videotape, which contained footage from surveillance cameras, by representing that a DVD copy was a fair and accurate copy of the original. Petitioner's trial attorney testified that he and petitioner viewed the DVD's poor quality images before trial, were aware the DVD disc was copied from the original surveillance video, and made no attempt to view the original. Further, an ATF agent had the DVD copy created for a legitimate purpose, viewed the copy after it was created, and concluded that it accurately represented what the original VHS tape depicted. Finally, the video was admitted to trial and petitioner failed to prove what additional information the jury would have gained by viewing the unenhanced original at trial. Accordingly, the court affirmed the judgment of the district court. The court granted petitioner's motion to supplement the appendix on appeal.
Court Description: Prisoner case - habeas. In a habeas where Masten produced expert testimony regarding whether an enhanced version of a videotape of her leaving the scene of the crime may have challenged the government's version of the offense, the district court did not err in rejecting Masten's claim that the government suppressed evidence in violation of Brady v. Maryland as Masten knew of the existence of the original videotape used to make the DVD shown at her trial and she chose not to view it; the prosecution reasonably believed the DVD accurately depicted the contents of the videotape and had no reason to believe the videotape contained exculpatory evidence; finally, the videotape was admitted at trial and Masten has failed to show what additional information the jury would have received from viewing the original, unenhanced version of the videotape as opposed to the DVD.
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