Kyles v. Whitley

Delores Dye was killed during a carjacking, and eyewitnesses gave police contradictory descriptions of the attacker. A man using the alias 'Beanie' claimed to have bought Dye's stolen car from Curtis Kyles (defendant) and gave police several inconsistent statements implicating him, but police never investigated Beanie himself; instead they found evidence in Kyles's apartment and trash, matched Kyles's fingerprint to a slip of paper in Dye's car, and had three of five witnesses identify his photo. Before trial, Kyles's attorney requested any exculpatory or impeachment evidence, and the prosecution said none existed. Kyles's first trial, in which he argued Beanie was framing him, ended in a mistrial; at the second trial, even with Beanie present in the courtroom, witnesses still identified Kyles, and he was convicted and sentenced to death. Only after his appeal did Kyles learn the prosecution had actually withheld favorable evidence, and after failing to get relief at the state level, he sought federal habeas corpus, which the district court denied and the court of appeals affirmed.