Rik Sargent v. Secretary, Florida Department of Corrections

Rik Sargent, a former Florida state prisoner currently on probation, appeals the district court’s denial of his petition for habeas relief, brought pursuant to 28 U.S.C. § 2254. In his petition, Sargent alleged that the state prosecutor failed to correct the false testimony of one of the state’s witnesses, a crime-lab toxicologist, during his criminal trial, in violation of Brady v. Maryland, 373 U.S. 83, 83 S.Ct. 1194, 10 L.Ed.2d 215 (1963), and Giglio v. United States, 405 U.S. 150, 92 S.Ct. 763, 31 L.Ed.2d 104 (1972). The district court concluded that there was no Giglio error because…