Whether the State's failure to disclose a centerpiece witness's psychiatric hospital admission constitutes a Brady violation warranting relief under due process principles

1. Whether the State’s failure to disclose that its centerpiece witness was admitted to a psychiatric hospital prior to testifying, which was discovered years later in a discharge summary that the State now concedes was Brady material, and thereby precluded the defense from exploring impeachment material on the only witness that could testify about the defend ant’s criminal actions alleged as no forensic evidence existed, is a violation under Brady v. Maryland, 373 U.S. 83 (1963) as such psyc hiatric admission disclosure should be deemed absolute and material pursuant to Kyles v. Whitley, 514 U.S. 419 ( 1995) and thereby overcoming any procedural de fect so as to assure a defendant receives due process. 2. Whether this Court sh ould clarify the discrepancy that exists between th e Second Circuit Court and Third Circuit Court regarding the Brady disclosure requirement by a state’s prosecuting unit of their centerpiece witness’s psychiatric records which could be used for impeachment purp oses where said witness’s testimony is the only evidence of the specific crimes charged.