Washingotn v. Mullen
Annotate this CasePetitioners Lisa Mullen and Kevin Dean were prosecuted for stealing funds from their employer, a Skagit County car dealership. At issue before the Supreme Court was the State's duty to disclose exculpating evidence to defendants. After their convictions, Petitioners obtained a previously sealed deposition of the dealership's accountant taken in a separate civil suit between the owner and the accountant's firm. The deposition took place before the end of the criminal trial. In a motion for a new trial, Petitioners argued that the accountant's deposition testimony supported the defense theory that the owner authorized use of the funds. Petitioners contended that the prosecution's failure to disclose the information from the deposition constituted a due process violation under "Brady v. Maryland," 373 U.S. 83. The appellate court affirmed the lower court's finding that there was no due process violation. The Supreme Court agreed after careful consideration of the trial record and the applicable legal authority. The Court found no "Brady" violation, and found that the trial court did not abuse its discretion by not granting Petitioners a new trial.
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