Prosecutors Receive Absurdly Lenient Sentence of Probation for Brady Violation That Resulted in an Innocent Man Spending More Than Four Years in Prison
by Douglas Ankney
The District of Columbia Court of Appeals gave prosecutors Mary Chris Dobbie and Reagan Taylor an absurdly lenient sentence of one year’s probation for deliberately withholding evidence that resulted in an innocent man spending four years in prison. In re Dobbie, 305 A.3d 780 (D.C. Cir. 2023). At the trial of two defendants accused of assault on an officer during a brawl inside the jail, Dobbie and Taylor withheld evidence that their lead witness – Corrections Officer Angelo Childs – had recently been demoted due to macing a man in custody who was already restrained. Childs then fabricated an incident report suggesting the maced man had assaulted an officer and assaulted a K9. But surveillance footage contradicted Childs’ account, and he was disciplined.
Dobbie and Taylor were provided a 10-page report (“Report”) from the Department of Corrections (“DOC”) that explained Childs’ actions, the DOC’s findings, and the punishment imposed. Under Brady v. Maryland, 373 U.S. 83 (1963), Dobbie and Taylor were required to disclose the Report to the defendants. Instead, because the Report revealed that their star witness had a history of making false allegations against detainees in the jail, the two prosecutors consulted their supervisor, Jeffery Ragsdale, Chief of Felony Major Crimes of the U.S. Attorney’s Office in D.C.
Ragsdale passed it along to John Roth, the head of a committee that advises on whether to call to the stand law enforcement officers who have credibility issues. Roth then inexplicably questioned the DOC’s conclusion that Childs had lied – but Roth cited nothing from the record to support his suspicions. However, Roth ultimately directed the prosecutors to disclose the Report to the defendants and challenge its admissibility at trial.
Instead, Ragsdale directed Dobbie and Taylor to file the Report under seal with the trial court and not reveal the contents to the defendants. He further instructed the two prosecutors to file a motion arguing that the defendants be prohibited from asking Childs about the Report during trial.
According to the D.C. Court of Appeals, Dobbie and Taylor “filed a misleading and factually incomplete motion.” Dobbie and Taylor filed only the first five pages of the Report, omitting the “most damning information about Childs” that began on the sixth page and the DOC’s findings on page 10. At the hearing on the motion, the judge sought confirmation that the five-page filing was complete. Dobbie answered that the copy she brought to court was five pages also. Taylor was present at the hearing with the 10-page report but said nothing. Based on the misrepresentations of Dobbie and Taylor, the trial court repeatedly denied the defendants’ requests for access to the Report.
Both defendants were convicted and sentenced to five years in prison. It took four years for the Report to eventually come to light. The D.C. Court of Appeals reversed one defendant’s conviction while the other one admitted he had been correctly identified. In 2021, the D.C. Board of Professional Responsibility unanimously recommended six-month suspensions for Dobbie and Taylor. However, in a divided opinion, the D.C. Court of Appeals reduced the sanction, citing in mitigation the deficient conduct of Ragsdale and Roth. No ethics charges were ever brought against Ragsdale or Roth. Ragsdale now heads the Justice Department’s Office of Professional Responsibility, and Roth went on to be the Inspector General for the Department of Homeland Security. The term “failing upward” comes to mind.
The most surprising aspect of this whole sordid saga that further undermines the little remaining respect Americans have for our “justice” system isn’t the absurdly lenient sentence imposed. It’s the fact that the prosecutors were disciplined at all. Rarely are prosecutors disciplined for deliberate misconduct that results in convicting the innocent (See CLN, July 2021, p. 7 & 10).
Source: theintercept.com
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Related legal case
In re Dobbie
| Year | 2023 |
|---|---|
| Cite | 305 A.3d 780 (D.C. Cir. 2023) |
| Level | Court of Appeals |
