Antoine D. Bates v. State of Indiana

Vaidik, Chief Judge.

Case Summary

At Antoine D. Bates’s jury trial for Class B felony burglary, the State disclosed for the first time that a wallet (which the owner had lost over two years earlier) had been found in the area of the burglary. Bates argued that this late disclosure violated Brady v. Maryland, 373 U.S. 83, 83 S.Ct. 1194, 10 L.Ed.2d 215 (1963), which requires the prosecution to disclose evidence that is favorable to the defendant. The trial court found no Brady violation, and Bates was convicted as charged. Bates now appeals, arguing a Brady violation and that the evidence is…