U.S. v. Morales

Defendant was not entitled to new trial on mail fraud charges stemming from scheme in which defendant obtained confidential bank information from victims and then withdrew funds from their accounts, even though prosecutor improperly withheld from defendant two emails indicating that: (1) defendant’s daughter was observed by police entering information into defendant’s laptop computer at time of execution of search warrant; and (2) police intended to arrest defendant and others when executing warrant. Neither email was material in sense that information in either email would have put defense of case in different light had either email been known prior to trial, given overwhelming nature of defendant’s guilt indicating that defendant had recruited individuals to assist in fraud scheme, falsified documents and collected profits from said fraud. Fact that defendant may not have entered information in his computer did not require different result, and defendant otherwise could have obtained from his daughter circumstances surrounding execution of search warrant.