The Supreme Court of Louisiana vacated four 23-year-old convictions and death sentences because the prosecution withheld impeachment and exculpatory evidence in violation of the defendant’s due process rights.

In 2001, Darrell J. Robinson was convicted of the murders of Billy Lambert, his sister Carol Hooper, her daughter Maureen Kelly, and Nicholas Kelly, Maureen’s infant son. According to court documents, Robinson met Lambert while they were both being treated for alcoholism at the Veteran’s Administration Center. Robinson moved into Lambert’s spare bedroom on May 20, 1996, eight days before the murders but started drinking again within days. The night before the murders, Lambert told his cousin that he was going to kick Robinson out of the house the next day and send him back to the VA because of his drinking.

At 8:30 a.m. on the day of the murders, Robinson bought a bottle of vodka at a nearby store. He was also seen parking Lambert’s truck at another store around 11:30 a.m.

At around 12:30 p.m., Lambert’s cousin, Doris Foster, arrived at Lambert’s home for a planned lunch with him, Hooper, Kelly, and her son. Lambert’s truck was parked in front of the house. Inside the house, Foster discovered the bodies of her relatives. Each had a gunshot wound to the head, and Lambert had been shot twice. Foster heard a noise from the back of the house, so she quickly left and called 911 from a nearby store. Returning with the first responders, Foster noticed that Lambert’s truck was missing.

The truck was seen spinning its wheels as it left the road Lambert’s house was on at around 12:15 p.m. Soon thereafter and 11 miles away, the truck, driven by Robinson, swerved into the lane occupied by Michael Poole’s vehicle, knocking his mirror off. He and a friend in another vehicle followed Robinson until the truck stalled at a traffic light.

Poole approached the truck, and a heated argument with Robinson ensued. When Robinson managed to restart the truck, he fled the scene, driving erratically and forcing other vehicles off the road. Poole called 911 while his friend pursued the truck.

The chase ended in the next parish when Robinson turned down a road, drove through a fence, parked behind a house, and fled on foot into the woods. Police found him there, hiding behind a mound of dirt about an hour and a half later. On his clothing were dirt, paint, and blood. Small spots of blood on his left shoe and the end of his left shoelace were consistent with the infant victim’s DNA.

Police found Lambert’s pocket knife and a pack of Marlboro Lights (Lambert’s brand of cigarettes) in Robinson’s pockets. In his wallet was $71 in cash. Despite an extensive search of Lambert’s house and the route Robinson took, no murder weapon was discovered.

In Lambert’s bedroom, police found a towel with stains of the infant’s blood. His wallet was on his dresser. It contained his identification and credit cards but no cash. Police found a bloodstained red jacket hanging on a doorknob near the victims. DNA testing determined the bloodstains were human but not Robinson’s or any of the victims’.

A gunshot residue expert examined Robinson’s clothes. Some particles of gunshot residue and lead were found on his pants legs in a pattern that was consistent with a right-handed person firing a gun downward.

Robinson was celled with Leroy Goodspeed at the jail. Goodspeed informed police that Robinson told him “he did those people, a man, two women, and a small child, and threw the gun off a bridge.” A .38 caliber revolver owned by Lambert was missing, and police theorized it had been used to kill the victims. Robinson was convicted of four counts of first-degree murder. The judge followed the jury’s unanimous recommendation and imposed the death penalty for each count.

During the trial, Foster testified that Lambert had given his gun, which he routinely kept next to his bed, to her for safekeeping while he was at the hospital. Because she is afraid of guns, she had him remove the bullets. When she returned it to him, she had accidentally left a bullet at her home, so the gun was loaded with only six bullets.

The State leaned heavily into this during trail. Its theory of that case was that, because there were only five gunshot wounds, the murder weapon was only loaded with five bullets and had to be Lambert’s missing pistol, which Robinson had known about.

Robinson argued he was not the perpetrator but had fled in shock and fear, much like Foster, after returning home and finding the bodies. No blood spatter was found on him, only minute transfer stains on the bottom of his left shoe and shoelace. He argued the lead and gunshot residue on his pants were either cross-contamination from a pat search or transfer from improper storage of his clothing.

Robinson proposed Mark Moras as the actual perpetrator and presented evidence that Moras had lived with Lambert two months prior to the murders. Lambert confronted Moras, who had been forging Lambert’s name on his checks. They fought, and Lambert shot at Moras while chasing him out of the house. Lambert reported the forged checks to police. Moras was arrested, but Lambert was murdered before the charges were resolved.

Robinson also challenged Goodspeed’s credibility, noting his drug addiction, extensive criminal history, mental health diagnoses and medications, and incidents of lying. Importantly, Goodspeed specifically denied gaining any benefit for his testimony.

The prosecutor called Goodspeed’s attorney in one of his cases that had been resolved to testify that Goodspeed’s testimony in the murder case had not been discussed during plea negotiations that resulted in a very favorable sentence. He also emphasized in closing arguments that Goodspeed gained nothing for his testimony.

Robinson’s convictions were upheld on direct appeal. His petition for post-conviction relief was denied. He successfully petitioned the Louisiana Supreme Court for a writ of certiorari.

The Court summarized the evidence that the prosecution failed to give to Robinson as marginal notes indicating the State was trying to help Goodspeed get out of jail; a letter from Goodspeed’s probation officer recommending that his probation not be revoked despite his being arrested for first-degree robbery; the fact that the State took the highly unusual step prior to Robinson’s trial of pardoning two of Goodspeed’s prior convictions, making him ineligible for the otherwise mandatory life sentence in the pending robbery case; evidence that the prosecutor left messages for a prosecutor in another parish where Goodspeed was facing first-degree robbery charges and had asked for leniency in two cases because Goodspeed was “an essential witness in a murder trial;” 54 pages of bench notes and diagrams from the crime lab’s serology report; and evidence that Goodspeed had cut a deal for his testimony and perjured himself about it.

Two statements were also not turned over to the defense. In one, a witness saw a different vehicle leave Lambert’s house the morning of the murders, and in another, a witness saw someone dropped off at Lambert’s house at noon or soon thereafter. In post-conviction follow-up, it was determined that the person the witness saw being dropped off was Lambert. Crucially, this put him arriving at the house after the murders were committed according to the prosecution’s timeline.

Part of the undisclosed lab notes discussed the importance of high-speed blood splatter being found on the outside of the red jacket. Post-conviction testing matched blood stains from the jacket’s lining to Moras, possible evidence that he wore it during the shooting. Further investigation showed Moras lied to an investigator about how he acquired knowledge of the murders.

The Court noted that the standard for reviewing this type of claim is set forth in Brady v. Maryland, 373 U.S. 83 (1963), holding that it is a violation of a defendant’s due process rights when a prosecutor withholds evidence favorable to the defense as to guilt or punishment, regardless of whether it was done with good or bath faith. This includes impeachment evidence. United States v. Bagley, 473 U.S. 667 (1985); State v. Kemp, 828 So.2d 540 (La. 2002). Further, the withheld evidence must be material in that it puts into question “whether he received a fair trial, understood as a trial resulting in a verdict worthy of confidence.” Kyles v. Whitley, 514 U.S. 419 (1995). That is, a Brady violation occurs when the “evidentiary suppression ‘undermines confidence in the outcome of the trial,’” and this determination is made by evaluating the cumulative effect of the withheld evidence. Id. 

However, the Court explained that “previously undisclosed evidence revealing that the prosecution introduced trial testimony that it knew or should have known was false” is subject to “a slightly lower standard of materiality under Brady.” United States v. Agurs, 427 U.S. 97 (1976). “Rudimentary principles of justice are offended, and due process is violated, when a prosecutor deceives a court and jurors with the presentation of known false evidence,” the Court stated. Giglio v. United States, 405 U.S. 150 (1972). The same holds true when the prosecution fails to correct false testimony. Napue v. Illinois, 360 U.S. 264 (1959). When this occurs, a new trial is required if “the false testimony could … in any reasonable likelihood have affect the judgment of the jury.” Id.

Turning to the present case, the Court determined that the State failed to disclose Goodspeed testified in exchange for beneficial treatment. It ruled that the evidence of a plea deal was material, and the State was obligated to disclose it.

The State tried to downplay its failure to disclose the lab notes and diagrams by stating that there was no evidence of the perpetrator being injured during the murders or of when the blood from Moras got on the jacket for which there was an alternate explanation, i.e., that it got on the jacket while he was working on Lambert’s farm. The Court, however, was unpersuaded by the State’s argument, stating that the State had “misconstrued its duty under Brady. Evidence need not be definitive to be exculpatory…. Here, the evidence is exculpatory in that it supports defendant’s theory of the case, i.e. that an unidentified person who was neither defendant nor one of the victims was present and involved in the murders.”

The District Court concluded that the State hadn’t committed a Brady violation, noting that the defense retained its own serology experts and had physical possession of the red jacket for testing and inspection. However, the Court disagreed, explaining that the defense’s access to the evidence and experts did not relieve the State of its obligation to disclose favorable evidence under La. C.C.P. art. 719(A).

One of the missing forensic notes was a Bullet Worksheet that the State claimed was not exculpatory. But firearms, ammunition, and gunshot residue expert John Nixon testified in a post-conviction hearing that the worksheet and undisclosed crime scene photos showing ricochet and divot marks supported a conclusion that six or more shots were fired by more than one shooter. This would have cast serious doubt on the State’s “five bullet theory.”

The District Court also erred when it analyzed the prejudicial impact of each item separately instead of evaluating the cumulative effect of exculpatory evidence as required by Kyles, the Court concluded.

The Court ruled that, because Goodspeed’s testimony was the only direct evidence linking Robinson to the murders, the withheld evidence that he lied about receiving favorable treatment for his testimony was material. Consequently, the State’s failure to correct the misleading testimony violated Robinson’s due process rights under Napue and Giglio, according to the Court.

Likewise, the withheld forensic evidence was material as were the undisclosed witness statements about another vehicle and Robinson being dropped off, the Court concluded. “Considered separately, each item undermines the strength of the State’s case. Considered cumulatively, they convince us that we can have no confidence that the jury’s verdict would not have been affected had the suppressed evidence come to light.” Thus, the Court held that Robinson did not receive a fair trial or a verdict worthy of confidence and is entitled to a new trial.

Accordingly, the Court vacated Robinson’s conviction and sentence and remanded for a new trial. See: State ex rel. Robinson Vannoy, 378 So.3d 11 (La. 2024).  

Editor’s note: Anyone interested in Brady violations is encouraged to read the Court’s full opinion, which discusses the governing law and painstakingly applies it to the facts of the case in far greater detail than is possible in this brief opinion summary.

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