People v. Smith, 10 N.Y.3d 303 (2008)
A prosecutor’s failure to disclose that the complaining witness in a rape and sodomy case had made a similar accusation against another individual, which the other individual denied, constitutes a Brady violation if there is a reasonable probability that the disclosure would have resulted in a different outcome at trial.
Summary
Defendant was convicted of sodomy after a trial where the complaining witness testified he forcibly performed oral sex on her. The prosecution failed to disclose that the same witness had accused another man of rape under similar circumstances shortly before the defendant’s trial. The New York Court of Appeals held that this non-disclosure violated the prosecution’s duty under Brady v. Maryland because the undisclosed evidence was material and could have affected the trial’s outcome, as it could have been used to impeach the complainant’s credibility and support the defendant’s claim that the encounter was consensual. The court reversed the Appellate Division’s order and granted the defendant’s motion to vacate his conviction, ordering a new trial.
Facts
The complainant accused the defendant of rape, sodomy, and sexual abuse following an encounter at his home. The defendant admitted to oral sex but claimed it was consensual, while the complainant alleged forcible compulsion. The complainant testified she met the defendant for the first time on the day of the incident and accepted his invitation to watch a movie at his house. Forensic evidence was inconclusive. The complainant’s father testified that his daughter once threatened to falsely accuse him of rape.
Procedural History
The defendant was convicted of sodomy in the first degree. Post-trial, the defendant discovered the complainant had accused another man, Parker, of rape in a similar incident. The defendant moved to vacate the conviction based on a Brady violation. The County Court granted the motion, but the Appellate Division reversed, finding the evidence inadmissible for impeachment. The New York Court of Appeals granted leave to appeal.
Issue(s)
Whether the prosecution’s failure to disclose that the complaining witness had accused another man of rape under similar circumstances constituted a suppression of material evidence favorable to the accused, violating the defendant’s due process rights under Brady v. Maryland.
Holding
Yes, because there is a reasonable probability that had the evidence been disclosed to the defense, the result of the trial would have been different.
Court’s Reasoning
The Court of Appeals found that the information about the complainant’s accusation against Parker was material. The court stated that the Appellate Division erred in focusing on Parker’s guilty plea to attempted rape months after the defendant’s trial because Brady obligations are assessed at the time of trial. The Court also stated that the Appellate Division read People v. Mandel too broadly. The court clarified that Mandel granted discretion to trial courts regarding the admissibility of prior false rape accusations, but it did not make such evidence inadmissible as a matter of law. The court emphasized that the information about Parker accusing the victim of willingly engaging in sex then lying about it would not have been an abuse of discretion for the trial court to admit. The court reasoned the information about Parker accusing the complainant of lying “might well have persuaded the jury to be significantly less skeptical of defendant’s story, and more skeptical of the complainant’s.” The court concluded that the Parker information was not cumulative, and even if similar to the father’s testimony about the daughter threatening to falsely accuse him of rape, the Parker information would not be insignificant. A jury might well find that three actual or threatened allegations of rape raised larger questions about the complainant’s credibility than two. As such, the court held that there was a reasonable probability that the non-disclosure affected the outcome of the trial.