Brooks v. State of Tennessee, 07-5415

Habeas petition from first degree murder conviction

Brooks v. State of Tennessee, 07-5415, concerned a challenge to the district court's denial of defendant's request for habeas relief, but grant of certificate of appealability, in defendant's request for habeas relief from his convictions for first-degree felony murder, especially aggravated robbery, theft of property, and setting fire to personal property.

In affirming, the court held that, although the issue of impeaching evidence concerning the "jailhouse snitch" is uncomfortably close to the constitutional line, the undisclosed evidence was not material under Brady.  Further, because defendant has not demonstrated that an agent's inaccurate testimony was material under the Brady-Napue-Giglio standard, he is not entitled to relief on his claim that the prosecution knowingly presented, and failed to correct, the false testimony of the agent concerning the fingerprint evidence.  Lastly, the court held that because the merits of defendant's claim depend entirely on the credibility of the informant's testimony, a rejection of that credibility necessitates a finding that defendant has not shown prosecutorial misconduct.

Related Link:

• Read the Sixth Circuit's Full Decision in Brooks v. State of Tennessee, 07-5415