The United States Supreme Court on Tuesday ordered a new trial for Juan Smith, who was convicted of first-degree murder after New Orleans prosecutors illegally failed to disclose evidence that the prosecution's key eyewitness told police he could not identify anyone involved in the crime.
Mr. Smith was convicted of five counts of first-degree murder based on the testimony of a single witness to the crime, who testified he had "no doubt" that Mr. Smith was the first of two gunman who entered a New Orleans home and shot five people during a robbery. No other witnesses and no physical evidence implicated Mr. Smith in the crime.
Mr. Smith later obtained files from the police investigation of his case, including the lead police investigator's notes stating that, on the night of the murders, the witness could not describe the perpetrators other than that they were black males and that, five days after the crime, the witness said he "could not ID anyone because [he] couldn't see faces" and "would not know them if [he] saw them." The police investigator's typewritten report also stated that the witness told him he "could not identify any of the perpetrators of the murder."
In 1963, the Supreme Court in Brady v. Maryland ruled that prosecutors must share with defense lawyers all of the evidence they have which might help the accused at trial. This rule is designed to prevent abuses of power by prosecutors that result in unreliable verdicts and miscarriages of justice. The Supreme Court has long held that the State violates the law if it withholds evidence that is favorable to the defense and material to the defendant's guilt or punishment.
In a four-page opinion by Chief Justice Roberts, the Court found in Smith v. Cain that, since the witness's testimony was the only evidence linking Mr. Smith to the crime, his undisclosed statements directly contradicting that testimony were "plainly material."
The 8-1 decision ordering a new trial for Mr. Smith is the latest in a series of cases challenging illegal conduct by prosecutors in Louisiana. Last April, the Court held in Connick v. Thompson that Louisiana prosecutors who failed to turn over exculpatory evidence could not be held liable for damages in a civil lawsuit where their admitted misconduct caused John Thompson to spend 14 years on death row -- and to nearly be executed on several occasions -- for a crime he did not commit.