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Klein v. Martin · ¶33

The panel majority first erred in holding that the state appellate court failed to apply the right rule for Brady materiality. Undisclosed evidence is material if it could reasonably have “ `put the whole case in such a different light as to undermine confidence in the verdict.' ” Strickler v. Greene, 527 U. S. 263, 290 (1999). But when the evidence could not have reasonably had such an effect, it is not material, and its erroneous nondisclosure does not justify relief. Under this rule, even if undisclosed evidence “entirely discredit[s]” a prosecution witness, the failure to turn over the evidence is not material if “considerable” other evidence “link[s]” the defendant to the crime and the record provides “strong support” that the defendant would have been convicted anyway. Id., at 292–294.
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