Carusone v. Warden, North Central Correctional Institution, No. 18-4175 (6th Cir. 2020)
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Carusone was convicted of felony murder exclusively on the theory—as the prosecution repeatedly emphasized in its closing argument at trial—that Carusone “plunged [a] knife into the victim’s heart.” That theory, as the state court of appeals later found, was “plainly discredit[ed]” by medical records that the state admits it wrongfully suppressed before trial. Those undisclosed hospital records contained a doctor’s affidavit that the victim “died as a result of cardiac arrest brought about by the combined effects of multiple drugs and alcohol and by heavy stress and exertion following a physical confrontation.” The state court of appeals denied Carusone relief.
The Sixth Circuit granted habeas relief. The state court “plainly misapplied the governing Supreme Court precedent,” in Brady v. Maryland and Kyles v. Whitley, when it held that the undisclosed evidence does not undermine confidence in the verdict. The reasoning of the court of appeals amounted to speculation that a jury would go further than any expert did, and find that “stress” from the stab wounds was a proximate cause of the victim’s death.
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