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Name: In re Miranda
Case #: S058528
Court: CA Supreme Court
District CalSup
Opinion Date: 05/05/2008

Under the 14th Amendment’s due process clause, the prosecution has a duty to disclose evidence to a criminal defendant when the evidence is both favorable and material on either guilt or punishment. In the death penalty portion of petitioner’s murder trial, the only evidence that the prosecution presented was the testimony of Joe Saucedo. Saucedo testified that petitioner, in addition to committing the capital murder, had also murdered another person in an unrelated matter. The jury found for death. After the conclusion of the capital case, petitioner pled guilty to second degree murder in this second case. Years later, after the Supreme Court had affirmed the death penalty and denied three habeas corpus petitions unrelated to the instant claim, attorneys for petitioner learned of a letter the prosecution had in its possession at the time of the capital case that it had not disclosed to the defense. The letter was from an inmate who had been in custody with Saucedo and advised that Saucedo told him that he had killed the second person. Further investigation revealed that, in addition to the letter, there were three other inmates to whom Saucedo had made statements implicating himself in the killing. The prosecution made arrangements with them providing benefits in exchange for their testimony against Saucedo in the event he was prosecuted. This information was also not disclosed to petitioner at the time of the capital case. Finding this evidence to be favorable and material and that the prosecution, therefore, had a duty to disclose it prior to the penalty phase of the capital trial, the court granted petitioner’s habeas corpus petition and vacated the judgment imposing death as well as the second degree murder conviction in the second case.