Dennis Riley v. Ohio
FifthAmendment JusticiabilityDoctri
whether-defendant-entitled-to-impeachment-or-exculpatory-evidence-after-pleading-guilty
QUESTIONS PRESENTED FOR REVIEW Petitioner was indicted on three felonies. He pleaded not guilty, requested and received discovery, and prepared for trial. Prior to trial, Petitioner changed his plea to guilty and was sentenced. Thirteen days after sentencing, the defense learned that the prosecution concealed and suppressed a substantial body of evidence which showed improper behavior by the only officer in the case. The defense expert was unchallenged in his opinion that the officer’s behavior was inappropriate and unacceptable. The Trial Court ruled that even though some of the suppressed evidence was impeachable evidence, it was not discoverable. The Court also held that the rest of the suppressed evidence was not exculpatory and, thus, not discoverable. The Fourth District Court of Appeals, Ohio, held, because the Defendant pleaded guilty, he was never entitled to impeachment or exculpatory evidence. The Ohio Supreme Court refused to review the case. The questions presented are: 1. Whether the court of appeals erroneously ruled that a defendant is not entitled to impeachment or exculpatory evidence if he pleads guilty at any stage of the proceeding, even after receiving discovery. ii 2. Whether the trial court below, after admitting evidence is impeachment evidence, erroneously held that Brady v. Maryland, 373 U.S. 83, 87 (1963), does not require impeachment evidence to be disclosed to the defense during discovery. 3. Whether the trial court below erroneously held that evidence of a personal and potentially intimate relationship between the only investigative officer and accuser in a criminal case is not evidence that is materially exculpatory for the defense and therefore is not required to be disclosed during discovery. 4. Whether the trial court below erroneously held multiple internal investigations conducted by the police and sheriff's departments into the only investigative officer’s conduct, character, and participation in alleged criminal activity is not materially exculpatory for the defense and therefore is not required to be disclosed during discovery. 5. Whether the court of appeals incorrectly stated that the petitioner did not claim that the suppressed evidence was exculpatory.