Munchinski v. Wilson, No. 11-3416 (3d Cir. 2012)
Annotate this CaseIn 1986 Munchinski was convicted of two counts of first-degree homicide and two counts of second-degree homicide arising out of a pair of murders that occurred in 1977 in Bear Rocks, Pennsylvania. Munchinski later discovered that prosecutors had withheld from his counsel almost a dozen articles of exculpatory evidence. After unsuccessfully petitioning for post-conviction relief several times in state and federal court, Munchinski filed a second or successive habeas petition pursuant to 28 U.S.C. 2244 & 2254(d), arguing that the Pennsylvania Superior Court unreasonably applied Brady, when it declined to grant Munchinski post-conviction relief. The district court granted habeas relief. The court equitably tolled the statute of limitations for some untimely claims; excused certain procedural defaults, finding that applying the procedural default doctrine would effect a fundamental miscarriage of justice; and agreed that the state court had unreasonably applied Brady. The Third Circuit affirmed, noting that the scope of the Brady violations was “staggering.” Munchinski demonstrated actual innocence by clear and convincing evidence.
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