People v. Letner and Tobin

In People v. Letner and Tobin (2010) 50 Cal.4th 99, the Supreme Court rejected a Brady claim where the prosecution failed to disclose one of its witnesses had an outstanding warrant for petty theft and, in a second case, had pleaded guilty to misdemeanor theft and writing a bad check. Acknowledging that "in general, a misdemeanor--or any other conduct not amounting to a felony--is a less forceful indicator of immoral character or dishonesty than is a felony" (People v. Wheeler, 4 Cal.4th at p. 296) Letner concluded the defendants "have failed to demonstrate that there is a reasonable probability that had the prosecutor disclosed to the defendants the then pending criminal matters facing the witness before the prosecution called her as a witness, the jury would have reached a result more favorable to the defendants. Accordingly, the defendants have not established that their constitutional rights were violated." (Letner, supra, 50 Cal.4th at p. 178.)