South Carolina v. Brown
Annotate this CaseCorey Brown was convicted by jury of conspiracy to commit grand larceny, armed robbery, and kidnapping. In a post-trial motion, Brown moved for a new trial on several grounds, including the State's failure to disclose its negotiations with Shadarron Evans, the State's key witness. The trial court granted the motion, and the State appealed. Agreeing with the State, the court of appeals reversed the grant of a new trial, concluding that no plea offer had been extended and remanded the case to the circuit court to make specific findings as to whether the evidence was material to Brown's guilt under Brady v. Maryland, 373 U.S. 83 (1963). The South Carolina Supreme Court granted Brown's petition for a writ of certiorari to review the decision of the court of appeals. After that review, the Supreme Court reversed and remanded the case to the circuit court for a new trial.
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