Strickler v. Greene

In Strickler v. Greene (1999) 527 U.S. 263, the nondisclosed evidence was closely analogous: documents were prepared by a witness (and a detective's notes of interviews with her) that could have impeached significant portions of her testimony. However, Strickler's determination that there was no Brady violation was because the court was convinced the totality of the relevant circumstances, including the testimony of three other witnesses placing the defendant around the crime scene and the "considerable forensic and other physical evidence linking the defendant to the crime" (Strickler, at p. 298), made it not reasonably probable the defendant would have obtained a more favorable result even had the witness been discredited. (Strickler, at pp. 263, 292-294.)