Michael C. Jamerson v. Jason Lewis, Warden
DueProcess HabeasCorpus
Did the Missouri courts err in failing to find that the State's failure to disclose exculpatory evidence violated its obligation under Brady v. Maryland, 373 U.S. 83 (1963), and that this failure prejudiced the defense?
QUESTION PRESENTED FOR REVIEW Petitioner Michael C. Jamerson’s trial was tainted by the State’s suppression of material exculpatory evidence and the prosecution’s use of perjured testimony. After the completion of Jamerson’s direct appeal and filing of his amended postconviction, evidence came to light that one of the State’s star witnesses, Catherine Haug, made an oral statement to the police that she had invited Jamerson over to her house on the night of the incident. It was not until David Columbo, the other complaining witness, sued Haug in state court for the injuries he suffered the night of the incident that her oral statement came to light. The State further violated Jamerson’s constitutional rights by allowing Haug to testify that she had not invited Jamerson over on the night in question. The Circuit Court, Court of Appeals, and Missouri Supreme Court denied petitioner habeas relief without conducting an evidentiary hearing or appointing a special master to review the newly discovered evidence. The questions presented are: I. Did the Missouri courts err in failing to find that the State’s failure to disclose exculpatory evidence violated its obligation under Brady v. Maryland, 373 U.S. 83 (1963), and that this failure prejudiced the defense? -ii II. Did the Missouri courts err in failing to find that the State’s failure to correct a witness's false testimony violated its obligation under Napue v. Illinois, 360 U.S. 264, 269 (1959), and Giglio v. United States, 405 U.S. 150, 155 (1972), and that this failure prejudiced the defense? -iii