Jay Smith v. John Holtz’s Empirical Analysis

Citation profile

11 federal appellate · 3 district · 1 state decisions

Most-quoted passages

The sentences later courts lift from this opinion, ranked by how many decisions quote each — the parts of the opinion doing the work. These counts are smaller than the citation total above because most of the 38 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. “[T]he term “Brady violation” is sometimes used to refer to any breach of the broad obligation to disclose exculpatory evidence — that is, to any suppression of so-called “Brady material” — although, strictly speaking, there is never a real “Brady violation” unless the nondisclosure was so serious that there is a reasonable probability that the suppressed evidence would have produced a different verdict. There are three components of a true Brady violation: The evidence at issue must be favorable to the accused, either because it is exculpatory, or because it is impeaching; that evidence must have been suppressed by the State, either willfully or inadvertently; and prejudice must have ensued.”

   3 later decisions quote this exact passage
   e.g. United States v. John · Government of the Virgin Islands v. Fahie

2. “[A] showing of materiality does not require demonstration by a preponderance that disclosure of the suppressed evidence would have resulted ultimately in the defendant’s acquittal (whether based on the presence of reasonable doubt or acceptance of an explanation for the crime that does not inculpate the defendant) ... [The] touchstone of materiality is a reasonable probability of a different result, and the adjective is important. 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, understood as a trial resulting in a verdict worthy of confidence. A reasonable probability of a different result is accordingly shown when the government’s evidentiary suppression undermines confidence in the outcome of the trial.”

   2 later decisions quote this exact passage
   e.g. Government of the Virgin Islands v. Fahie · 285 F. Supp. 2d 454 - Morelli v. United States

3. “[T]he individual prosecutor has a duty to learn of any favorable evidence known to the others acting on the government's behalf in the case, including the police.”

   2 later decisions quote this exact passage
   e.g. Thomas v. City of Phila. · Gibson v. Superintendent of New Jersey Department of Law & Public Safety-Division of State Police