Narrative Opinion Summary
The First Circuit Court of Appeals addressed the legal standards for granting a new trial based on newly discovered evidence, particularly focusing on the unwitting use of perjured testimony. The appellant, convicted of attempted possession and conspiracy to distribute cocaine, sought a new trial after it was revealed that key government witnesses had misrepresented their identities. The appellant argued that the government failed to meet its disclosure obligations under Brady v. Maryland and that the district court misapplied the standard for newly discovered evidence. The appellate court affirmed the district court's decision, applying the 'probability' standard that requires the newly discovered evidence to likely result in acquittal upon retrial. The court rejected the appellant's argument for the more lenient Larrison rule, which has been criticized and rejected by several circuits. Additionally, the appellate court upheld the district court's calculation of the appellant's sentencing range, finding no clear error in the assessment of drug quantity based on witness testimony. The court concluded that the prosecution's failure to disclose the witnesses' true identities did not materially affect the outcome, and thus, did not warrant a new trial.
Legal Issues Addressed
Application of the Larrison Rulesubscribe to see similar legal issues
Application: The court rejected the appellant's argument for the Larrison rule, adhering instead to the probability standard for newly discovered evidence in cases of perjured testimony.
Reasoning: The district court considered the appellant's argument but ultimately rejected the Larrison rule, determining his claims did not meet either the standard for knowing prosecutorial use of perjury or the traditional newly discovered evidence standard.
Assessment of Drug Quantity for Sentencingsubscribe to see similar legal issues
Application: The court upheld the district court's drug quantity determination, finding that testimony provided by witnesses was credible and supported by a preponderance of the evidence.
Reasoning: The court upheld the reliance on Morel's testimony regarding drug quantity, affirming that an approximate estimate can be valid as long as it is a reasoned assessment.
Disclosure Obligations Under Brady v. Marylandsubscribe to see similar legal issues
Application: The court determined that the prosecution's failure to disclose the witnesses' true nationalities did not violate Brady because the information was not materially exculpatory.
Reasoning: Even if it could be considered impeachment evidence, the failure to disclose such evidence does not warrant a new trial unless the appellant can demonstrate that there is a reasonable probability the outcome would have been different had the evidence been disclosed.
Standard for Granting a New Trial Based on Newly Discovered Evidencesubscribe to see similar legal issues
Application: The court adopted the 'probability' standard, requiring that the discovery of both perjured testimony and its correction would probably result in acquittal upon retrial.
Reasoning: The court concluded that the 'probability' standard should apply, stating that for a motion for a new trial based on such claims, it must be shown that the discovery of both the perjured testimony and its corrected version would probably result in acquittal upon retrial.