Reversal was required for Brady error where the government suppressed evidence of subsequent robberies by a similar looking robber while the defendant was in custody. The appellate court reversed the district courts denial of a motion for a new trial following a conviction for armed bank robbery and use of a firearm during an armed bank robbery. The court held that evidence suppressed by the government (that, after defendants arrest, two other banks were robbed by a woman whose description bore an uncanny physical resemblance to the defendants) was, viewed in the context of the entire record, material. Also, the defendant was prejudiced by the suppression and under Brady v. Maryland, the government therefore deprived the defendant of a fair trial.
Case Summaries