United States v. Dones-Vargas, No. 18-2600 (8th Cir. 2019)
Annotate this CaseThe Eighth Circuit affirmed defendant's conviction for two drug trafficking offenses. The government had been unaware of payments that local police made to a cooperating witness and thus failed to disclose the information to the defense. Defendant moved for a new trial based on the nondisclosure. The court held that the undisclosed payments were not material to the outcome of the proceeding and thus the district court did not err by denying defendant's motion for a new trial. In this case, the impeachment value of the payment information was not so devastating as to undermine the entire prosecution.
Court Description: Colloton, Author, with Kelly and Erickson, Circuit Judges] Criminal case - Criminal law. Undisclosed payments to a cooperating witness were not material to the outcome of the case, and the district court did not err in denying defendant's motion for a new trial based on the government's failure to disclose them; nondisclosure of the relatively small payments in these circumstances, when considered against the backdrop of the government's substantial case, does not undermine confidence in the jury's verdict; the impeachment evidence was not material and the defendant has not established a violation of the Due Process Clause.
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