State v. Ieng

A person who is convicted of a crime is not entitled to a new trial solely because a key prosecution witness recants important trial testimony. If the recantation is not credible, then it is not material, and an essential factor that would support a new trial is missing. Here, Kea Ieng, who was convicted of first degree murder, fails to show that the trial court abused its discretion by deciding, under the totality of the circumstances, that the testimony of the recanting witness was not credible. Accordingly, we affirm.

In January 1991, Kea Ieng shot and killed Him Chhom just outside the Ieng…