Swear on the Stand
This episode from the Fifth Circuit Court of Appeals details the reversal of a lower court's decision to dismiss fraud charges against Sade Kuyoro. The defendant was originally accused of disaster relief fraud involving Hurricane Harvey funds, but the district court dismissed the indictment after the government failed to timely disclose recoupment letters and details regarding a property inspector. However, the appellate court determined that these late disclosures did not constitute Brady violations because the defendant was not unfairly prejudiced and could have discovered the information through reasonable diligence. The ruling emphasizes that dismissing an indictment is an extreme sanction that was not warranted here, especially since the trial judge found no malicious intent by prosecutors. Consequently, the appellate court ordered the reinstatement of the indictment to allow the criminal case to proceed.
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