## Facts

- Virginia charged Tommy David Strickler with capital murder, robbery, and abduction arising from the January 5, 1990 abduction, robbery, and murder of college student Leanne Whitlock.
- Strickler and a codefendant were tried separately and convicted; Strickler was convicted of capital murder and sentenced to death.
- At trial, prosecution witness Anne Stoltzfus gave detailed testimony about the abduction and Strickler’s role.
- Police files contained interview notes and Stoltzfus letters to a detective that significantly undermined parts of her trial account and could have been used for impeachment.
- The defense did not receive these materials before trial and did not file a specific pretrial request for exculpatory evidence, relying on the prosecution’s “open file” policy.
- In federal habeas proceedings, Strickler obtained the undisclosed materials; the district court granted relief based on an asserted Brady violation.
- The Fourth Circuit reversed, ruling the Brady claim procedurally defaulted and meritless.

## Issues

1. Whether the State’s failure to disclose impeachment materials relating to a key witness constituted a violation of Brady v. Maryland.
2. Whether Strickler showed “cause” to excuse his failure to raise the Brady claim in state court.
3. Whether Strickler showed “prejudice” sufficient to excuse procedural default and to satisfy Brady materiality.

## Decision

- The Supreme Court affirmed the Fourth Circuit’s denial of federal habeas relief.
- The Court held Strickler established cause for not raising the Brady claim earlier because he reasonably relied on the State’s open-file policy and representations that all exculpatory material had been disclosed.
- The Court held Strickler failed to establish prejudice/materiality because, despite the impeachment value of the suppressed materials, there was not a reasonable probability of a different result at guilt or sentencing.
- Because prejudice was not shown, the procedural default was not excused and, on the merits, no Brady violation was established.

## Legal Principles

- A “true Brady violation” requires: (1) favorable evidence (exculpatory or impeaching), (2) suppression by the State (willful or inadvertent), and (3) resulting prejudice.
- Evidence is material under Brady only if there is a reasonable probability that, had it been disclosed, the result of the proceeding would have been different; the question is whether the verdict remains worthy of confidence.
- The “cause and prejudice” standard for overcoming procedural default is closely tied to Brady’s materiality inquiry; failure to show prejudice defeats both.
- An open-file policy does not eliminate Brady obligations, but reasonable reliance on such a policy can support a finding of cause when nondisclosure is later discovered.

## Conclusion

The Court concluded that withheld impeachment evidence met Brady’s favorability and suppression components and supplied cause for procedural default, but it was not material because it did not create a reasonable probability of a different outcome; therefore, Strickler could not show prejudice, and habeas relief was denied.


Strickler v. Greene, 527 U.S. 263 (1999)