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Name: Horton v. Mayle
Case #: 03-56618
Court: US Court of Appeals
District 9 Cir
Opinion Date: 05/10/2005

A defendant is entitled to habeas relief where the prosecution failed to disclose a deal between the police and a crucial witness. The district court here had failed to hold an evidentiary hearing on the claim, holding that as a matter of law, a defendant would not be entitled to relief because evidence of such an agreement is not material under Brady v. Maryland. The Ninth Circuit disagreed, holding that because the witness’s testimony was central to the prosecution case, the California Supreme Court’s summary dismissal of the Brady claim was an unreasonable application of clearly established Supreme Court precedent.