04/03/2015
CJAD 405
MADDOX V. MONTGOMERY
United States Courts of Appeals,
Eleventh Circuit 718 F.2d 1033
(11th Cir. 1983)
Facts:
Jimmy Maddox was sentenced to serve a life of imprisonment after he was convicted in a Georgia State court for charges of rape. Maddox filed for a federal Habeas corpus petition after being unsuccessful at a direct appeal for his charges. His reason behind filing the federal habeas corpus was for the court violating the doctrine of Brady v. Maryland for alleging prosecutorial suppression of exculpatory evidence. The Brady doctrine applies to this case in 4 areas; “1) The prosecutor has not disclosed information despite a specific defense request; 2) the prosecutor has not disclosed information despite a general defense request for all exculpatory information or without any defense request at all; 3) the prosecutor knows or should know that the conviction is based on false evidence; 4) the prosecutor fails to disclose purely impeaching evidence not concerning a substantive issue, in the absence of a specific defense request,” (Ingram 2015, pg 781). United States V. Anderson required proof that the accused believed that some particular "official proceeding" was likely to occur in the near future, and was incorrectly instructed that an "official proceeding" includes an investigation.
Issue:
Maddox declared that his rights to due process were violated as it is stated in the doctrine of Brady v. Maryland. This violation is proven by the state failing to disclose a photograph taken by the police of Elder’s bed neatly made shortly after the alleged rape. The police found no blood, semen, or fluids of other kinds on the bedspread during an examination, no rape kit was used either, and proof of a letter was found that Debbie Phillips had left the insurance Maddox belonged to for financial reasons by way of a written statement from a witness by the name of Brenda Phelps. Maddox had appealed the denial of habeas relief.
Decision of
Citations: to Support Judgment: Brady v. Maryland, 373 U.S. 83 (1963). United States v. Anderson, 574 (5th Cir. 1978). United States v. Kopituk, 690, 1289, 1339 (11th Cir. 1982). United States v. Kubiak 1551, (11th Cir. 1983). United States v. Blasco, 464, U.S. 914, (1983). Ingram, J. (2015). Criminal Evidence (12th ed., p. 781). Amsterdam: Elsevier.