Federal 7th Circuit Court
Criminal Court
Evidence
Dist. Ct. erred in denying defendant's habeas petition challenging his murder conviction on grounds that prosecution wrongfully withheld three exculpatory eyewitness statements that implicated another individual as the actual shooter. Dist. Ct. applied wrong standard of proof on materiality element under Brady that improperly required defendant to show that withheld evidence would have established his innocence. Moreover, Dist. Ct. failed to consider cumulative effect of suppressed evidence, which was otherwise sufficient to show reasonable probability of different result at trial.