Supreme Court Reverses Another Louisiana Murder Conviction Because Prosecutors Withheld Evidence

On January 10, the U.S. Supreme Court reversed (8-1) the murder conviction of Juan Smith because the New Orleans District Attorney’s Office had withheld critical evidence that would have been favorable to Smith at his trial. Smith had been convicted of murder in the course of an armed robbery based on the sole eyewitness testimony of Larry Boatner. There was no DNA, fingerprints, or other physical evidence that linked Smith to the 1995 crime. Appellate attorneys later learned that prosecutors failed to disclose reports of initial interviews with Boatner in which he said he could not describe the intruders and had not seen their faces. Relying on Brady v. Maryland, which requires a state to disclose evidence that is favorable to the defense and material to the defendant’s guilt or punishment, the Court overturned Smith’s conviction, stating, “Boatner’s testimony was the only evidence linking Smith to the crime. And Boatner’s undisclosed statements directly contradict his testimony … .Boatner’s undisclosed statements were plainly material.” The decision in favor of Smith was the latest in a series of Supreme Court decisions revealing a pattern of prosecutorial misconduct in the Orleans Parish District Attorney’s Office. According to the Orleans Public Defender’s Office, 28 convictions obtained by the district attorney’s office were later ruled to have been tainted by Brady violations. (Smith is on death row in Louisiana because the conviction in the above case (now overturned) was used to help obtain a death sentence against him in another murder. This decision will likely assist him in challenging his death sentence.)

Justice Clarence Thomas dissented, saying it was unlikely the withheld evidence would have made a difference in the jury’s deliberations about Smith’s guilt.

(A. Liptak, “High Court Reverses Conviction in Killings,” New York Times, January 10, 2012; Read the U.S. Supreme Court opinion (Smith v. Cain, No. 10-8145). See Supreme Court and Arbitrariness.