Juan Matthews v. Louisiana

Under Brady v. Maryland, 373 U.S. 83 (1963), prosecutors must disclose favorable evidence to the defense to safeguard the defendant’s right to a fair trial. The State violates Brady when it suppresses evidence that is “material” to guilt or punishment. Kyles v. Whitley, 514 U.S. 419, 433 (1995). This Court has stressed that the materiality inquiry “is not a sufficiency of evidence test.” Id. at 434 (emphasis added). That is because “the possibility of an acquittal” does not necessarily turn on whether there is “an insufficient evidentiary basis to convict.” Id. at 435. A court thus errs if it rejects a Brady claim because it thinks “the remaining evidence” could “support the jury’s conclusions.” Strickler v. Greene, 527 U.S. 263, 290 (1999). A court must instead consider how the suppressed evidence would have affected the case, and ask whether the “suppression ‘undermines confidence’ ” in the verdict. Kyles, 514 U.S. at 434 (citation omitted). Louisiana state courts nevertheless routinely apply a sufficiency-of-the-evidence test to Brady claims. See, e.g., State ex rel. Robinson v. Vannoy, 397 So. 3d 333, 358 (La. 2024) (asking whether “there was sufficient other evidence upon which defendant’s conviction was based”); State v. Brown, 347 So. 3d 745, 836-838 (La. 2022) (rejecting Brady claim by emphasizing the “overwhelming” and “copious” evidence presented at trial). The question presented is: Whether the Louisiana courts erred by denying Petitioner Juan Matthews’s Brady claim based on the sufficiency of the evidence at trial.