A Claim That the Detectives to Whom a Person Had Confessed Had Engaged In Criminal Activity
In Breedlove v. State, 580 So. 2d 605 (Fla. 1991), an appellant who had been charged with and convicted of murder alleged that a Brady violation occurred when the State failed to disclose that the detectives to whom the appellant had confessed had engaged in criminal activity (drug conspiracy and drug use) unrelated to the appellant's case.
The detectives were subsequently investigated by the internal affairs division of their police department for this alleged criminal activity.
The court rejected the appellant's claim because it failed to meet the materiality prong of Brady (violation).