State v. Williams

Citations

• 2025 ND 46

Syllabus

A Brady violation is established when the defendant proves the government possessed evidence favorable to the defendant, the defendant did not possess the evidence and could not have obtained it with reasonable diligence, the prosecution suppressed the evidence, and a reasonable probability exists that the outcome of the proceedings would have been different if the evidence had been disclosed. To prevail on a Brady claim a defendant must satisfy all four prongs or factors of the legal test. When an issue is not raised at the trial court, this Court will not address the issue on appeal unless the alleged error rises to the level of obvious error. A defendant's due process rights may be violated by a prosecutor's actions that constitute misconduct that has a prejudicial effect.