Cited by

“Evidence is material under Brady if there is a reasonable probability that, had the evidence been disclosed to the defense, the result of the proceeding would have been different.” (quotations omitted).

must meet all three requirements to establish a Brady violation.”

if proven at an evidentiary hearing, must meet all three requirements to establish a Brady violation.”

must meet all three requirements to establish a Brady violation.”

A reasonable probability is one that is sufficient to undermine confidence in the outcome.” Zornes v. State , (quotations and citation omitted).

To establish a Brady violation, a defendant must show (1) the evidence is favorable to him because it would have been either exculpatory or impeaching; (2) the evidence was suppressed by the prosecution, intentionally or otherwise; and (3) the evidence is material, “in other words, the absence of the evidence must have caused prejudice to the defendant.” (quotation omitted).

Respondent’s intentional or unintentional suppression of “material evidence favorable to the defendant violates the constitutional guarantee of due process.” Zornes v. State

“Evidence is material under Brady if there is a reasonable probability that, had the evidence been disclosed to the defense, the result of the proceeding would have been different.” (quotations omitted).

“Evidence is material under Brady if there is a reasonable probability that, had the evidence been disclosed to the defense, the result of the proceeding would have been different.” (quotations omitted).

1 A defendant “must meet all three requirements to establish a Brady violation.”

“Evidence is material under Brady if there is a reasonable probability that, had the evidence been disclosed to the defense, the result of the proceeding would have been different.” (quotations omitted).

if proven at an evidentiary hearing, must meet all three requirements to establish a Brady violation.”

“Evidence is material under Brady if there is a reasonable probability that, had the evidence been disclosed to the defense, the result of the proceeding would have been different.” (quotation omitted).

(explaining that because “the trial transcript clearly shows that Zornes’s sister did testify at trial, the postconviction court’s finding is clearly erroneous”).

DECISION We review the denial of “a petition for postconviction relief for an abuse of discretion.” (quotation omitted).

“Evidence is material if there is a reasonable probability that, had the evidence been disclosed to the 8 defense, the result of the proceeding would have been different.” Zornes v. State , (citation omitted) (internal quotatio n marks omitted).

at *3 (citing Zornes v. State , ).

See also Zornes v. State , (applying this same standard).

A Brady violation occurs when (1) the evidence is favorable to the defendant; (2 ) the state withheld the evidence , “intentionally or otherwise ;” and (3) the evidence is material because its absence would “have caused prejudice to the defendant .”

(“Because [defendant]’s attempt to invoke the Knaffla exceptions is merely an argumentative assertion without factual support, it fails as a matter of law.”).

(quoting Brown v. State , , 617 (Minn. 2017) ); Zornes v. State , , 416 (Minn. 2017).

See Zornes v. State , , 421 (Minn. 2017) (explaining that unraised claims that "should have been known" may be barred).

A claimed exception must be based on more than “an argumentative assertion without factual support”; otherwise, “it fails as a matter of law.”

P. 9.01 provides that the state must disclose any written or recorded statements which relate to the case “within the possession or control of the prosecution” as well as any “[m]aterial or information in the prosecutor’s possession and control that tends to negate or reduce the defendant’s guilt.” 6 (quotation omitted).

Zornes v. State , , 416 (Minn. 2017).

“[T]he suppression by the State, whether intentional or not, of material evidence favorable to the defendant violates the constitutional guarantee of due process.” (alteration in original) (quotation omitted).

See Zornes v. State , -21 (Minn. 2017).

Zornes v. State , , 416 (Minn. 2017) (quoting Carridine v. State , , 492 (Minn. 2015) ).

Zornes v. State , , 416 (Minn. 2017) (quotation omitted).