Dennis Riley v. Ohio

Petitioner was indicted on three felonies. He pleaded not guilty, requested and received discovery, and prepared for trial. Prior to trial, Petitioner changed his plea to guilty and was sentenced. Thirteen days after sentencing, the defense learned that the prosecution concealed and suppressed a substantial body of evidence which showed improper behavior by the only officer in the case. The defense expert was unchallenged in his opinion that the officer’s behavior was inappropriate and unacceptable. The Trial Court ruled that even though some of the suppressed evidence was impeachable evidence, it was not discoverable. The Court also held that the rest of the suppressed evidence was not exculpatory and, thus, not discoverable. The Fourth District Court of Appeals, Ohio, held, because the Defendant pleaded guilty, he was never entitled to impeachment or exculpatory evidence. The Ohio Supreme Court refused to review the case. The questions presented are: 1. Whether the court of appeals erroneously ruled that a defendant is not entitled to impeachment or exculpatory evidence if he pleads guilty at any stage of the proceeding, even after receiving discovery.