Nondisclosure Not Material to Warrant Reversal in Murder Trial.
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Nondisclosure of Uncharged Criminal Conduct Not Material to Warrant Reversal in Murder Trial
“Even though the government failed to provide a defendant on trial for murder with evidence of a key government witness’s uncharged crimes so that his attorney could cross-examine the witness on promises and inducements he may have expected to receive in exchange for his testimony, the Rhode Island Supreme Court held that such a withholding was not “material” and would not have changed the jury’s guilty verdict. The Court held that even though the prosecutor at the time had been involved in other cases that were later overturned because he deliberately withheld evidence from the defense, this case did not warrant reversal for similar alleged Brady violations.”