John Koehler v. Secretary Pennsylvania Department of Corrections

Summary

The Court affirmed the denial of Koehler's federal habeas petition, holding that the Pennsylvania Supreme Court reasonably rejected his Brady claim concerning an alleged non-prosecution agreement with witness Kirk Schrader. The state court reasonably found that any agreement had been revoked before Schrader testified, that the defense had access to the relevant evidence, and that the evidence was not material in light of the remaining proof. The Court also declined to revisit Koehler's separate Napue/Giglio claim.