In re Colorado v. OwensAnnotate this Case
Sir Mario Owens and Robert Ray petitioned the Supreme Court in its original jurisdiction for relief from a series of discovery rulings of the district court in their respective death-penalty cases relating to post-conviction proceedings. Each moved to discover the prosecution's investigation of claims raised by Owens' motion for post-conviction review, on grounds that disclosure was required by the state rules of criminal procedure or the federal and state constitutions. The district court held that Crim. P. 16 did not impose obligations on the prosecution with respect to its preparation to meet defendants' post-conviction claims, but that the prosecution did have obligations to disclose information that was both exculpatory and constitutionally material. The Supreme Court held that the district court did not err in finding it inapplicable to information acquired in response to defendants' post-conviction claims. However, because the Court had not previously held that only a prosecutor's constitutional obligation to disclose extended through the appeal of a death sentence, the district court should order disclosure of some possibly exculpatory material despite being unable to find a reasonable probability that nondisclosure would change the result of the proceedings. The cases were remanded for the district court to review defendants' constitutional claims.