Jefferson v. United States, No. 12-1182 (6th Cir. 2013)
Annotate this CaseAn internal investigation by the U.S. Attorney’s Office found evidence suggesting that during the Jefferson trial on drug-conspiracy charges, the prosecution failed to disclose to the defense the extent of the promises of leniency that the prosecution made to cooperating witnesses. In a motion to vacate his sentence, 28 U.S.C. 2255, Jefferson alleged that he was denied a fair trial because the prosecutor violated his obligation under Brady v. Maryland to disclose material impeachment evidence. Following a remand, the district court again denied Jefferson’s motion, finding that Jefferson’s claims were not timely filed, that equitable tolling was not warranted, and that even if timely, Jefferson’s Brady claims failed on the merits. The Sixth Circuit affirmed that the claims filed on the merits, because the material at issue was not prejudicial. The court rejected the conclusion that Jefferson failed to exercise due diligence in these circumstance. A section 2255 petitioner is permitted to rely on the government’s representation that it has fulfilled its Brady obligations. Reasonable diligence does not require a section 2255 petitioner repeatedly to scavenge for facts that the prosecution is unconstitutionally hiding from him.
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