## Facts

- In March 1992, Roger de la Burde died of a single gunshot wound to the head.
- Beverly Anne Monroe, de la Burde’s longtime girlfriend, was tried in Powhatan County, Virginia, and convicted of his murder after a highly publicized prosecution.
- After trial, Monroe discovered evidence she contended had been withheld by the prosecution and law enforcement, including:
  - impeachment material concerning prosecution witnesses,
  - leads suggesting other suspects,
  - official documents labeling the death a suicide, and
  - statements indicating de la Burde may have been suicidal.
- Monroe asserted the withheld information was favorable to the defense and central to disputing the State’s homicide theory.

## Issues

1. Whether the prosecution suppressed favorable evidence and, if so, whether the cumulative nondisclosure was material under Brady.
2. Whether federal habeas relief was permitted under AEDPA because the state court’s Brady adjudication was contrary to, or an unreasonable application of, clearly established federal law.
3. Whether the court of appeals had jurisdiction over Monroe’s cross-appeal challenging the district court’s procedural-default rulings after she had already obtained habeas relief.

## Decision

- The Fourth Circuit affirmed the district court’s grant of Monroe’s 28 U.S.C. § 2254 petition.
- The court held that the State suppressed favorable evidence and that, considered cumulatively, the suppression was material because it undermined confidence in the verdict.
- The court concluded the state court’s rejection of the Brady claim amounted to an unreasonable application of clearly established federal law for purposes of § 2254(d)(1).
- The court dismissed Monroe’s cross-appeal for lack of jurisdiction because she had already received the operative relief, making further review of additional theories non-dispositive.

## Legal Principles

- Brady requires disclosure of evidence favorable to the accused, including exculpatory and impeachment material, when the evidence is suppressed by the State and is material.
- Materiality is assessed cumulatively: the question is whether there is a reasonable probability that disclosure of all suppressed evidence would have produced a different result, such that nondisclosure undermines confidence in the outcome.
- On federal habeas review, relief may be granted under AEDPA when the state court’s adjudication unreasonably applies clearly established Supreme Court precedent governing Brady.
- An appellate court lacks jurisdiction to decide a cross-appeal that would not affect the relief already awarded and would functionally amount to advisory review.

## Conclusion

The Fourth Circuit upheld habeas relief because the prosecution withheld a significant body of exculpatory and impeachment evidence—including materials supporting suicide and alternative-suspect theories—that was material when considered together, and it dismissed the petitioner’s cross-appeal because the requested additional review would not alter the relief granted.


Monroe v. Angelone, 323 F.3d 286 (4th Cir. 2003)