Codianna v. Morris

In Codianna v. Morris, 660 P.2d 1101, 1106 (Utah 1983), the prosecution failed to voluntarily disclose eleven depositions, four witness statements, and an unrecorded witness statement. To determine whether this failure was a constitutional violation meriting post-conviction relief, the Court asked whether the evidence "created a reasonable doubt of petitioner's guilt when viewed in the context of the entire trial record." Although the petitioner claimed that the evidence was exculpatory, the Court concluded that because the evidence was "tangential or cumulative, and did not create a reasonable doubt of petitioner's guilt" in the context of the record, there was no violation of due process in the prosecution's failure to disclose.