Juniper v. Zook

The Fourth Circuit vacated the district court's denial of relief under 28 U.S.C. 2254 as to petitioner's Brady claim, holding that the district court abused its discretion in dismissing the claim without holding an evidentiary hearing because it failed to assess the plausibility of that claim through the proper legal lens. In this case, withheld witness materials were exculpatory and impeaching evidence that was unquestionably subject to disclosure under Brady. The court reasoned that, by failing to disclose such evidence before trial, and unjustifiably continuing to resist its disclosure for years thereafter, the prosecution arrogated to itself a central function belonging to the criminal jury and pursued its roles as adversary to the exclusion of its role as architect of a just trial. Accordingly, the court remanded to the district court for further proceedings. View "Juniper v. Zook" on Justia Law