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Smith v. Cain | 565 U.S. 73 (2012)

In the landmark case of Brady versus Maryland, the Supreme Court held that a state violates due process when a prosecutor suppresses evidence material to a criminal defendant’s guilt or punishment. In Smith versus Cain, the Supreme Court considered what makes evidence material under this standard.

Juan Smith was charged with the murders of five people during an armed robbery. At trial, the sole evidence linking Smith to the crimes was the testimony of a single witness. Larry Boatner testified that he was visiting a friend when three gunmen entered the home. After demanding drugs and money, the men began shooting, killing five of Boatner’s friends. Boatner identified Smith as the first of the three gunmen to enter the house.

Smith was convicted on five counts of first-degree murder. On appeal, the Louisiana Court of Appeal affirmed his convictions, and the Louisiana Supreme Court and the United States Supreme Court denied review. After Smith sought postconviction relief in the state courts, he received files related to the investigation of his case. The investigation notes of lead detective John Ronquillo directly conflicted with Boatner’s testimony. Ronquillo’s written account of his interview with Boatner days after the murders stated that Boatner couldn’t describe any of the gunmen beyond the fact that they were three black males. Ronquillo’s notes also stated that Boatner claimed he wouldn’t be able to identify any of the gunmen if he saw them again.

The trial court denied Smith’s request to vacate his conviction, and the state appellate courts denied review. The Supreme Court granted cert.

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