In Maharaj v. Dep’t of Corrections, No. 04-15669 (Dec. 15, 2005), the Court affirmed the denial of habeas relief to a Florida inmate sentenced to life in prison for murder.
Procedurally, the Court declined to enter a stay in view of ongoing collateral proceedings in state court involving the Vienna Convention. The factors involved in such a determination did not weigh in the petitioner’s favor.
The Court held that the district court did not err in considering alleged Brady violations individually, instead of for their cumulative effect. Thus viewed, the Court found no error. For instance, the witholding of a potentially exculpatory polygraph test of the State’s lead witness was not a Brady violation, because defense counsel was sufficiently aware of the test to cross-examine the witness about it. Applying the deferential habeas standard of review, the Court found no error.
The Court also found no error in the failure to provide defense with the murder victims’ briefcase, finding that the defense could have subpoenaed these materials. The Court also noted that the contents of the briefcase were not "material" to the case.
The Court also found no reversible error in the failure of authorities to comply with the Vienna Convention. The Court noted that it was not bound by holdings of the International Court of Justice, and that there was no established Supreme Court precedent at odds with the State court holdings.
