Canales-Yanez v. StateAnnotate this Case
The Court of Appeals affirmed the judgment of the court of special appeals affirming the denial of Defendant's motion for new trial on the grounds that certain newly discovered evidence was immaterial, holding that there was no Brady violation in this case.
Defendant was convicted of two counts of first-degree murder. Following the trial but prior to sentencing, the State informed Defendant's counsel of an interview that took place between two detectives and the family members of one of the State's witnesses. Defendant moved for a new trial, arguing that the nondisclosure of the interview violated Brady v. Maryland, 373 U.S. 83 (1963). The circuit court denied the motion, finding that the evidence of the interview was not material. The Court of Appeals affirmed, holding that the nondisclosure of the interview did not constitute a Brady violation.