Comstock v. Humphries, No. 14-15311 (9th Cir. 2015)
Annotate this CasePetitioner appealed the district court's denial of his habeas petition. The district court, however, granted a certificate of appealability on petitioner's Brady v. Maryland claim. Petitioner was found guilty of possessing stolen property - a ring commemorating Randy Street's 1991-1992 national college wrestling championship. Petitioner received a 10-25 year sentence under Nevada's habitual offender statute. Street told the prosecutor and the detective that he may have taken the ring off outside and left it there. Rather than share this evidence with the defense, the prosecution suppressed it. The court concluded that Street's recollections that he shared with the State before trial were favorable to petitioner and suppressed to petitioner's prejudice. Accordingly, the court reversed and remanded with instructions for the district court to grant the writ of habeas corpus.
Court Description: Habeas Corpus. The panel reversed the district court’s judgment denying Stephen Comstock’s habeas corpus petition challenging his Nevada conviction for possessing stolen property—a ring commemorating Randy Street’s 1991-1992 national college wrestling championship. The panel held that Comstock is entitled to relief under Brady v. Maryland based on the prosecution’s failure to disclose that, prior to trial, Street told the prosecutor and the investigating detective that the ring might have been lost outside, not stolen from his apartment, just as Comstock’s lawyer had argued to the jury. The panel held that Street’s recollections were favorable to Comstock in that they impeached the credibility of Street’s trial testimony as to how he handled his ring, and more importantly, affirmatively cast serious doubt on whether there was a crime in the first place. The panel also held that the recollections were suppressed. The panel concluded that the suppression was prejudicial because had the information been disclosed, there is at least a reasonable probability that the outcome of the trial would have been different. The panel held the state court’s contrary conclusion was an unreasonable application of Brady and its progeny. COMSTOCK V. HUMPHRIES 3 The panel instructed that on remand the writ of habeas corpus be granted, setting aside Comstock’s conviction and sentence, and that Comstock be released from probationary custody unless the State notifies the district court within 30 days that it intends to retry him, and commences retrial within 90 days.
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