Brady Violation.

Byline: Derek Hawkins

7th Circuit Court of Appeals

Case Name: United States of America v. Torrie King, et al.

Case No.: 16-1275; 16-2260; 16-3084; 16-4212

Officials: FLAUM, RIPPLE, and BARRETT, Circuit Judges.

Focus: Brady Violation

Nathaniel Hoskins, Julian Martin, and Torrie King were members of the Imperial Insane Vice Lords, a gang in Chicago. Following a multi-year investigation into the gang's activities, they were prosecuted together in a bench trial and convicted on several counts. After trial and before sentencing, the government disclosed evidence that it had obtained from a confidential informant.

The district court held that the late disclosure did not violate Brady v. Maryland, 373 U.S. 83 (1963), because the suppressed evidence was neither exculpatory nor material. All three defendants appeal that ruling. In addition to the joint Brady claim, Martin raises two issues that are unique to him: he argues that the district court violated the Confrontation Clause when it admitted a statement made by a non-testifying codefendant and that the district court made several...