Connolly v. State
Former FBI agent John Connolly, convicted of second-degree murder, appealed denial of his Rule 3.850 motion alleging the State violated Brady by failing to disclose an email in which a witness relayed another witness's opinion that Connolly was innocent. The Third District affirmed, holding that while the State suppressed the favorable email, Connolly failed to show prejudice/materiality given the overwhelming evidence of guilt, the declarant's unavailability and inadmissible hearsay affidavit, and the fact that much of the underlying information was equally available to the defense through reasonable diligence.
Key facts
- Former FBI agent John Connolly was convicted of second-degree murder in the trial court.
- Connolly appealed the denial of his Rule 3.850 motion alleging the State committed a Brady violation by failing to disclose an email in which a witness relayed another witness's opinion that Connolly was innocent.
- +2 more key facts with a free trial
Why it matters
This opinion offers a useful template for Brady materiality analysis in cases involving unavailable witnesses and hearsay affidavits submitted in postconviction proceedings, reaffirming that affidavits of deceased or… — full analysis with a trial
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