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Hill v. Mitchell
Brief of the National Association of Criminal Defense Lawyers as Amicus Curiae in Support of Petitioner (on petition for writ of certiorari).
Argument: The Sixth Circuit’s new relation back standard erects an arbitrary barrier to the amendment of Brady claims. It is irreconcilable with the language of Rule 15, its purpose, this Court’s decision in Mayle v. Felix, the standard applied in civil litigation, and the standards applied in other circuits. Given the grave threat to the integrity and fairness of the criminal justice process, and the importance of consistent application of the Federal Rules, this Court should grant the petition and clarify a uniform standard for Rule 15’s relation back provision. The State acknowledged that it suppressed exculpatory evidence in Mr. Hill’s case. And the case arises in Hamilton County, Ohio, where a long history of Brady violations has been well-documented and is beyond dispute. The district court judge and two of the three judges on the Sixth Circuit panel agreed that Mr. Hill’s Brady claim could succeed on the merits. It was the majority’s new interpretation of Rule 15 that barred his claim. Because this case offers the Court a clean shot at resolving a question of great importance that divides the lower courts, the petition should be granted.