White v. Steele, No. 16-2349 (8th Cir. 2017)
Annotate this CasePetitioner, convicted of first degree murder, armed criminal action, and first-degree assault, appealed the district court's denial of his 28 U.S.C. 2254 petition for habeas relief. Petitioner argued that the State failed to disclose that a key prosecution witness received favorable consideration in exchange for his testimony. The court noted that, even if it had reason to doubt compliance with the statute of limitations in this case, the court proceeded to the merits in the interest of judicial economy. On the merits, the court concluded that the State did not violate Brady v. Maryland nor Napue v. Illinois where nothing in the factual findings indicated that the district court's finding that no formal or tacit agreement existed between the State and the witness was reasonable. The court assumed that the financial assistance the witness received for staying in a hotel for one week and relocating to another apartment was subject to Brady's disclosure mandate. However, failure to disclose this information here did not violate Brady because it did not undermine confidence in the verdict. Accordingly, the court affirmed the denial of habeas relief.
Court Description: Gruender, Author, with Riley, Circuit Judge, and Schreier, District Judge] Prisoner case - Habeas. Even though the court had reason to doubt the petition was filed within the applicable AEDPA statute of limitations, it would consider the merits of White's claims in the interest of judicial economy; the state did not violate Brady or Napue by failing to disclose an agreement with a prosecution witness that did not exist; assuming without deciding that financial assistance provided to the witness was subject to disclosure under Brady, White was not entitled to habeas relief as the failure to disclose the information did not undermine confidence in the guilty verdict. [ April 05, 2017
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