materiality standard (Missouri) · Go Syfert
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materiality standard in Missouri

17 Missouri opinions name it 2 courts 1986–2024 2 in the last five years

The cases below were cited by Missouri courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (7)

CaseFollowedCited
Kyles v. Whitleygreen
scotus · 1995 · cited in 10 Missouri opinions naming this issue, 2006–2024
2 sentences

2024The materiality standard for Brady claims is established when "the favorable evidence could reasonably be taken to put the whole case in such a different light as to undermine confidence in the verdict." Kyles, 514 U.S. at 435 .

2020“The materiality standard for Brady claims is established when ‘the favorable evidence could reasonably be taken to put the whole case in such a different light as to undermine confidence in the verdict.’” Id. (quoting Kyles v. Whitley, 514 U.S. 419, 435 (1995)).

510
Hancock v. Shookgreen
mo · 2003 · cited in 2 Missouri opinions naming this issue, 2006–2007
2 sentences

2007Hancock v. Shook, 100 S.W.3d 786, 798 (Mo. banc 2003).

2006Hancock v. Shook, 100 S.W.3d 786, 798 (Mo. banc 2003).

22
State v. Howardgreen
moctapp · 1999 · cited in 1 Missouri opinions naming this issue, 2023–2023
1 sentence

2023See McLaughlin, 988 S.W.2d at 545 (holding that if the legislature had intended to require the State to prove that the information sought to be suppressed was or would be material, it presumably would have set forth such a requirement in the statute, as it has for other crimes, and to “judicially engraft a materiality requirement would be inconsistent with the recognized purpose of the statute”).

11
Taylor v. Stategreen
mo · 2008 · cited in 1 Missouri opinions naming this issue, 2010–2010
2 sentences

2010See Taylor v. State, 262 S.W.3d 231, 244 (Mo. banc 2008) (noting “[t]he fact that a witness was impeached in other ways does not conclude the materiality inquiry required under Brady ” because the witness’s credibility is not a collateral issue).

2010“In determining whether the suppressed impeachment evidence was material, the reviewing court must evaluate not only the ways that [the witness] was impeached, but also the ways that he was not impeached that would have been available had [the Brady claim] evidence been disclosed.” Id.

11
Black v. Stategreen
mo · 2004 · cited in 1 Missouri opinions naming this issue, 2008–2008
2 sentences

2008This Court has specifically recognized that impeachment evidence is not cumulative "when it goes to the very root of the matter in controversy or relates to the main issue." Black v. State, 151 S.W.3d 49, 56 (Mo. banc 2004).

2008This Court has specifically recognized that impeachment evidence is not cumulative “when it goes to the very root of the matter in controversy or relates to the main issue.” Black v. State, 151 S.W.3d 49, 56 (Mo. banc 2004).

11
State v. Hedgegreen
moctapp · 1990 · cited in 1 Missouri opinions naming this issue, 1999–1999
1 sentence

1999As the court stated in State v. Hedge, 793 S.W.2d 478, 480 (Mo.App.1990), “anything which obstructs the procurement of witnesses, or, once procured, which hinders their freedom and willingness to speak the truth before any court or body charged with the enforcement of our laws, civil or criminal, is an offense against the administration of justice and is within the contemplation of Chapter 575.” Even if the information suppressed may ultimately prove to be immaterial, the damage to the system lies in depriving the proper authorities of the opportunity to make that judgment.

11
State v. Aarongreen
moctapp · 1999 · cited in 1 Missouri opinions naming this issue, 1999–1999
1 sentence

1999See Aaron, 985 S.W.2d at 436 ; Carter, 939 S.W.2d at 557 .

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Missouri. Read the followed side critically anyway.

Also cited on this issue (6)

CaseCitedYears
State Ex Rel. Engel v. Dormire green
mo · 2010
2 sentences

2024Engel v. Dormire, 304 S.W.3d at 128 (quoting Kyles v. Whitley, 514 U.S. 419, 435 (1995)).

2013Thus, our Supreme Court has held that: The materiality standard for Brady claims is established when “the favorable evidence could reasonably be taken to put the whole case in such a different light as to undermine confidence in the verdict. [ ] The question is not whether the defendant would more likely than not have received a different verdict with the evidence, but whether in its absence he received a fair trial ... resulting in a verdict worthy of confidence.” Engel, 304 S.W.3d. at 128 (quoting Kyles, 514 U.S. at 434-35 , 115 S.Ct. 1555 ) (emphasis added).

32013–2024
Strickler v. Greene green
scotus · 1999
2 sentences

2020“The materiality standard for Brady claims is established when ‘the favorable evidence could reasonably be taken to put the whole case in such a different light as to undermine confidence in the verdict.’” Id. (quoting Kyles v. Whitley, 514 U.S. 419, 435 (1995)).

2014Id. at 290 , 119 S.Ct. 1936 .

22014–2020
United States v. Bagley green
scotus · 1985
2 sentences

1999Bagley, 473 U.S. at 682 , 105 S.Ct. 3375 .

1999Bagley, 473 U.S. at 682 , 105 S.Ct. 3375 .

11999–1999
State v. Cummings green
moctapp · 1992
1 sentence

1999As discussed, swpra, in the perjured-testimony situation of nondisclosure, the third element of a due process claim based thereon, that the prosecution obtained a conviction based on known perjured testimony, Cummings, 838 S.W.2d at 7 , is required to encompass the materiality standard of the Brady rule, that the alleged perjured testimony undermined the confidence in the jury’s verdict of guilty.

11999–1999
State v. Carter green
moctapp · 1997
1 sentence

1999See Aaron, 985 S.W.2d at 436 ; Carter, 939 S.W.2d at 557 .

11999–1999
United States v. Agurs green
scotus · 1976
2 sentences

1986In United States v. Agurs, 427 U.S. 97 , 96 S.Ct. 2392 , 49 L.Ed.2d 342 (1976), the Court further explained the materiality requirement: The proper standard of materiality must reflect our overriding concern with the justice of the finding of guilt.

1986In United States v. Agurs, 427 U.S. 97 , 96 S.Ct. 2392 , 49 L.Ed.2d 342 (1976), the Court further explained the materiality requirement: The proper standard of materiality must reflect our overriding concern with the justice of the finding of guilt.

11986–1986

Where else courts name it

TX 168 (1975–2026) CA 102 (1899–2026) DE 66 (1985–2026) IL 40 (1934–2026) PA 39 (1980–2026) MD 38 (1982–2025) VA 36 (1987–2026) NJ 28 (1963–2025) WA 25 (1983–2024) MI 22 (1971–2026) NY 22 (1851–2026) LA 20 (1982–2025) FL 19 (1985–2019) CO 18 (1983–2025) DC 17 (2001–2025) TN 17 (2000–2025) OH 17 (1987–2026) MO 17 (1986–2024) ID 14 (1985–2022) NC 14 (2006–2023) WI 13 (1978–2023) CT 11 (1960–2024) MN 9 (1982–2024) UT 8 (1991–2025) MS 8 (1987–2013) IN 8 (1988–2016) KS 8 (1961–2024) MA 8 (1985–2020) OR 8 (1985–2024) NV 6 (1994–2016) GA 6 (2021–2026) AL 5 (1989–2015) IA 5 (2011–2026) MT 5 (1998–2016) KY 5 (1982–2025) NE 4 (1998–2025) SC 4 (2004–2018) AZ 4 (1985–2018) SD 4 (2020–2025) HI 3 (2000–2023) ND 3 (1981–2016) WV 3 (1998–2018) WY 3 (1992–2025) RI 3 (1975–1998) VT 2 (1987–2001) NM 2 (1994–2025) ME 2 (2008–2013) OK 2 (2015–2015)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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