Joseph Allen Maldonado-Passage v. United States

Whether due process and this Court’s precedents (Napue v. Illinois, Giglio v. United States, Kyles v. Whitley) require a federal trial court to hold an evidentiary hearing before denying a Rule 33 motion for new trial where multiple sworn post-trial recantations by accusing witnesses admit perjury and reveal undisclosed inducements, where the credibility of those witnesses was decisive at trial.

Whether a court of appeals violates Kyles v. Whitley, 514 U.S. 419 (1995), when it rejects a Brady claim by evaluating each suppressed item in isolation rather than cumulatively, particularly where suppressed impeachment evidence, corroborated recantations, and physical-evidence irregularities collectively undermine confidence in a criminal verdict.

Whether an appellate court may invoke the invitederror or waiver doctrine to bar review of the legal standard a district court applied in denying a Rule 33 new-trial motion when (a) the law in that circuit was unsettled, (b) the defendant advanced alternative standards below, and (c) the doctrine thus precludes review of whether the correct legal rule governed the outcome.