State v. SotoAnnotate this Case
The Supreme Court reversed the judgment of the district court rejecting Defendant's claim that he was entitled to a new trial without holding a hearing on the merits of his claim pursuant to Brady v. Maryland, 373 U.S. 83 (1963), holding that the district court abused its discretion by denying Defendant's motion on the grounds that he was not legally authorized to hear the merits of the Brady claim.
In his motion, Defendant alleged that important information undermining the testimony of the State's star trial witness came to light for the first time while the case was on remand to the district court for resentencing. The trial court denied the motion without a hearing, concluding that the request for relief based on the Brady claim fell outside the statutory time limit. The Supreme Court reversed, holding (1) Kansas' mandate rule did not deprive the district court of subject matter jurisdiction to address the merits of Defendant's claims; and (2) there was no final judgment under Kan. Stat. Ann. 22-3501(1) in this case, and therefore, the district judge failed to recognize that he was legally authorized to hear the merits of the Brady claim.