Case Brief MADDOX V

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Columbia College *

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405

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Law

Date

Apr 3, 2024

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docx

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4

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1 Maddox v. Montgomery United State Court of Appeals Eleventh Circuit 718 F. 2d 1033 Brett A. Sagel CJAD 405: Laws of Criminal Evidence Judge Daniel D’Alesio March 15, 2024
2 Facts : The appellant Jimmy Maddox was sentenced to life in prison for a rape conviction in Georgia. The appellant filed a Federal Writ of Habeas Corpus alleging a violation of his 5 th amendment right to due process by the prosecution failing to release exculpatory evidence, despite the appellant making no such request, as required in Brady v. Maryland, 373 U.S. 83, 83 S. Ct. 1194, 10 L. Ed. 2d 215 (1963). The prosecution failed to release three pieces of circumstantial evidence which would have placed a level of doubt in the jury. The evidence in question was a photograph of the victim’s bed taken by police shortly after the incident showing the bed neatly made, the results of a police examination of the bed spread showing no evidence of bodily fluids, and a statement from Brenda Phelps, which discredited a statement from Debbie Phillips. The statement from Phillips stated that she dropped the insurance provided by the appellant due to his sexual advances and the statement from Phelps alleged that Phillips had dropped the insurance policy due to financial reasons. The appellant claimed he had an ongoing sexual relationship with the victim and the event in question was consensual. Issue: Did the prosecution violate the appellant’s 5 th amendment right to due process by failing to release the exculpatory evidence based on Brady v. Maryland? Decision: The Eleventh Circuit affirmed the decision of the state court denying the habeas petition of the appellant. The court stated the evidence did not provide sufficient grounds to alter the outcome of the case.
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