Smith v. Cain Summary (Murder Homicide; Armed Robbery; Criminal Defenses)

In the case of SMITH v. CAIN, the U.S. Supreme Court on January 10, 2012 (Case #10-8145), reversed the Decision of the Louisiana State Trial Court, which erroneously convicted the defendant of first-degree murder based upon the testimony of a single witness. At trial, the only witness to link the defendant to the crime untruthfully claimed he was face to face with the defendant during the initial moments of an armed robbery, and identified Smith as the first gunman to come through the door when two other gunmen entered the residence in question. There were no other witnesses and no physical evidence to implicate the defendant in the crime.

During a state post-conviction proceeding, the defendant obtained police files containing exculpatory statements by the eyewitness that contradicted his trial testimony, which evidence was not disclosed by the prosecution in the Discovery they provided to the defendant’s counsel. The police investigator’s notes made at both the time of the murder as well as five days later contained statements by this sole witness that he could not supply a description of the perpetrators other than they were black males, as he could not see their faces and further that he would not know any of them even if he saw them. The notes were so damaging to the prosecution it was a clear travesty of justice for the prosecution to have failed to provide this evidence to the defense. The U.S. Supreme Court concluded the prosecution’s failure to disclose those statements violated the legal precedent established in the 1963 case of Brady v. Maryland, 373 U. S. 83, which held due process bars a State from withholding evidence that is favorable to the defense and mate­rial to the defendant’s guilt or punishment.