## Facts

- Louisiana charged Juan Smith with killing five people during an armed robbery in New Orleans.
- At trial, the prosecution’s case depended on one eyewitness, Larry Boatner, who identified Smith as the first gunman to enter and testified he was face to face with Smith at the start of the robbery.
- The State presented no physical evidence tying Smith to the crime and no other eyewitness identification; Boatner’s identification was the only evidence linking Smith to the murders.
- After conviction, Smith obtained police notes showing Boatner had previously stated he could not describe the perpetrators beyond that they were Black males, could not identify anyone because he could not see their faces, and would not know the perpetrators if he saw them.
- The State had not disclosed these prior statements to the defense before trial.

## Issues

1. Whether the State violated due process under Brady by failing to disclose favorable impeachment statements from the only eyewitness connecting Smith to the crime.
2. Whether the suppressed statements were material—i.e., whether their disclosure creates a reasonable probability of a different trial result sufficient to undermine confidence in the verdict.

## Decision

- The Supreme Court reversed and remanded in an 8–1 decision.
- The Court held the State violated Brady by suppressing Boatner’s prior statements.
- Favorability and nondisclosure were undisputed; the case turned on materiality.
- The Court found the statements “plainly material” because they directly contradicted the eyewitness’s trial identification and the eyewitness testimony was the only evidence linking Smith to the crime.
- The Court found it unnecessary to address other allegedly suppressed evidence once the Boatner statements established a Brady violation.

## Legal Principles

- The prosecution violates due process when it suppresses evidence favorable to the accused that is material to guilt or punishment.
- Evidence is material if there is a reasonable probability that, had it been disclosed, the result of the proceeding would have been different; a reasonable probability is one sufficient to undermine confidence in the verdict.
- Impeachment evidence may be immaterial when other evidence is strong, but it can be material when it attacks the reliability of the only evidence connecting the defendant to the crime.
- Prior statements by a key eyewitness disclaiming an ability to identify the perpetrator can constitute material Brady impeachment evidence when they contradict the witness’s trial identification.

## Conclusion

The Court held that the State’s suppression of the sole eyewitness’s prior statements—statements that repudiated any ability to identify the perpetrators—was material impeachment evidence under Brady, requiring reversal because the nondisclosure undermined confidence in the guilty verdict.


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