State v. Huebler

Charles Huebler was convicted, pursuant to a guilty plea, of lewdness with a child under fourteen years of age. Huebler subsequently filed an untimely post-conviction petition for writ of habeas corpus, alleging that he had good cause for his delay in filing the petition because the State improperly withheld surveillance videotapes that were exculpatory, which rendered his guilty plea involuntary. The district court granted relief to Huebler. The Supreme Court reversed, holding (1) the State is required under Brady v. Maryland to disclose material exculpatory evidence within its possession to the defense before the entry of a guilty plea; (2) a defendant may challenge the validity of the guilty on the basis of the State's failure to make the required disclosure, but to succeed, the defendant must demonstrate the three components of a Brady violation in the context of a guilty plea; (3) as to the materiality component, the test is whether there is a reasonable probability that but for the State's failure to disclose the evidence the defendant would have refused to plead guilty and would have gone to trial; and (4) Huebler failed to demonstrate that the evidence was material under the materiality component.