Cone v. Bell, 556 U.S. 449 (Apr. 28, 2009)

Although exculpatory evidence suppressed by the state was immaterial to the jury’s finding of guilt, it might have affected the jury’s decision to recommend a death sentence. The defendant offered an insanity defense based on his habitual use of an excessive amount of drugs and their affect on his behavior during the commission of the offenses. After the defendant was convicted and sentenced to death, it was discovered that the state had suppressed exculpatory evidence concerning the defendant’s drug use. The Court remanded to the federal habeas trial court for a full review of the suppressed evidence and its effect on sentencing.