First Circuit: US v. Calderon

Brady, Grand Juries


Undisclosed evidence was not dispositive -- court below did not impose a sufficiency of the evidence test in in asking whether the suppressed evidence was dispositive of the verdict.

Knowledge of plea deal in second jurisdiction cannot be imputed to the prosecution in the first jurisdiction as the basis for a Brady claim.

Absent grave prosecutorial misconduct, guilty verdict at trial means that there was sufficient probable cause for the indictment.


US v. Calderon