Mario Dion Woodward v. Alabama

This postconviction capital case involves a claim under Brady v. Maryland, 373 U.S. 83 (1963), where the State of Alabama improperly withheld evidence that law enforcement had investigated an alternative perpetrator for the underlying crime. The Alabama Court of Criminal Appeals rejected the Brady claim, finding that the alternative-perpetrator evidence was immaterial, that the claim was barred by two statelaw statutes of limitation, and that Defendant Mr. Woodward failed to meet Alabama’s heightened requirements for pleading a state-law newly discovered evidence claim. The questions presented are:

1. Whether a state court in a postconviction proceeding may summarily deny a Brady claim for failure to meet Brady’s materiality standard based on the alleged failure to plead how the withheld evidence of an alternative perpetrator “would have countered the State’s significant evidence of guilt.”

2. Whether a state court in a postconviction proceeding may arbitrarily apply state-law statutes of limitation and pleading requirements to bar a Brady claim based on evidence material to a capital conviction first discovered during the postconviction phase.