Rodriguez: Conjugal visits not material

In Rodriguez v. Sec., Fla. Dep’t of Corrections, No. 11-13273 (June 30, 2014), the Court affirmed the denial of habeas relief to a Florida inmate sentenced to death for three 1984 murders. The Court rejected Rodriguez’ claim that detectives testified falsely about conjugal visits that a cooperating State witness was allowed. The Court agreed with the Florida courts that this evidence “lacked materiality.” The Court also noted the defense’s “withering cross-examination” of this witness. The Court also rejected a claimed Brady violation involving the withhold of two letters that would have cast doubt on a prosecution witness. The Court concluded that the letters were “not material.”