People of Michigan v. Schuyler Dion Chenault

Summary

The Michigan Supreme Court rejected a diligence requirement added by the Court of Appeals to the Brady framework, overruled that precedent, and reaffirmed the traditional three-factor test requiring suppressed, favorable, and material evidence. Although the videotaped interviews were suppressed and favorable because they could have impeached witnesses and undermined the identification, they were not material because the cumulative evidence still produced a verdict worthy of confidence. The same lack of prejudice defeated the defendant’s ineffective-assistance claim.