United States v. Stampe, No. 19-6293 (6th Cir. 2021)
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Stampe and Loden were charged with conspiring to distribute at least 500 grams of methamphetamine. Stampe pled guilty and agreed to cooperate with the government in its case against Loden. Before Stampe’s sentencing, the government dropped Loden’s case after “discover[ing] circumstances apart from evidence of . . . guilt which prevent[ed] . . . moving forward.” The government told Stampe that Loden’s dismissal did not affect its case against her; the dismissal related to inappropriate conduct by a confidential informant. Stampe moved to compel the government to disclose the information that led to the dismissal of Loden’s conspiracy charge or to review that evidence in camera and moved to withdraw from her plea agreement.
Relying on government representations both that the informant’s misconduct happened after Stampe’s arrest and that the government had complied with disclosure obligations, the district court denied Stampe’s motions. The Sixth Circuit affirmed. Even assuming Stampe said enough to trigger Rule 16 or Brady disclosure in the abstract, her arguments fail because of the court’s reliance on the government’s representations that items sought were immaterial. While Stampe believed that she might avoid some prison time because of her putative cooperation in Loden’s case, the plea agreement did not require that possibility; it was not the “principal purpose” of the agreement.
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