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United States v. Kenneth Edward Stuart
Citations: 150 F.3d 935; 1998 U.S. App. LEXIS 17476; 1998 WL 432481Docket: 97-1671
Court: Court of Appeals for the Eighth Circuit; July 31, 1998; Federal Appellate Court
Kenneth Edward Stuart was convicted of making false statements to a firearms dealer and possessing a firearm as a felon, resulting in a concurrent 15-year sentence for each count, 3 years of supervised release, and a $100 special assessment. Stuart appealed, claiming the district court wrongfully denied his motion for a new trial based on the alleged suppression of exculpatory evidence. The case stemmed from a 1994 transaction where Stuart completed ATF Form No. 4473, falsely answering that he had not been convicted of a felony. Evidence included expert testimony confirming his handwriting on the form and records from the Arkansas Department of Corrections detailing his prior felony convictions. A fellow inmate testified that he purchased the rifle but claimed Stuart helped him fill out the form due to lack of identification. Stuart denied completing the form but acknowledged signing it, asserting he lent money for the purchase. After conviction, Stuart sought a new trial based on an affidavit from Cartina Manning, who claimed the rifle belonged to the inmate, not Stuart. The district court ruled Manning's testimony was neither suppressed nor material, leading to the appeal focusing on whether the government's failure to disclose this testimony violated Brady v. Maryland. The appellate court affirmed the lower court's decision, stating it would only overturn the denial of a new trial if there was an abuse of discretion. A Brady claim requires the appellant to prove three elements: (1) the government suppressed evidence, (2) the evidence was favorable to the defense, and (3) the suppressed evidence was material to guilt or punishment. Evidence is not considered suppressed if the defendant could have accessed it through reasonable diligence. If a defendant fails to obtain available evidence due to a lack of diligence, no Brady claim exists, even if the evidence is material or exculpatory. In this case, the government provided appellant with Prevo's grand jury testimony three months before trial, which included references to Manning's testimony about Prevo bringing a rifle to her house. Appellant had the chance to review Manning's full testimony but did not do so. The court concluded that the government did not suppress the testimony, and the district court acted within its discretion by denying the motion for a new trial. Therefore, the district court's judgment is affirmed.