Repository Collection 03

State v. McDowell

CASE ENTRY

Last Revised • July 10, 2026

This Source Verification Page documents the North Carolina Supreme Court's decision in State v. McDowell, cited in Claim II of the Supplemental Motion. The opinion discusses the constitutional materiality standard governing undisclosed favorable evidence and explains when nondisclosure requires a new trial because it likely would have created a reasonable doubt that otherwise did not exist.


Related SMAR Citation

“[State v. McDowell, 310 S.E. 2d 304 (N.C. 1984)]”


Case Name

State v. McDowell


Citation

310 S.E. 2d 304 (N.C. 1984)


Date

January 10, 1984


Verification Source

Official United States Court of Appeals for the Fourth Circuit opinion


Source Location

North Carolina Supreme Court opinion


Highlighted Pages

8, 10


Referenced in the Supplemental Motion

Page 56 - 57, Paragraph: 118


Source Status

✔ Original Court Order obtained and reviewed.

✔ Relevant passages highlighted.

✔ Publicly available source

✔ Included within the Source Verification Archive


Cited to Support

May's allegation that when the prosecution fails to disclose favorable evidence that was not specifically requested by the defense, the proper materiality standard is whether the undisclosed evidence would likely have created a reasonable doubt in the jury's mind that did not otherwise exist when considered alongside all of the other evidence presented at trial. If so, due process requires a new trial. May cites State v. McDowell to support his claim that the materiality of suppressed evidence depends upon its probable effect on the jury's verdict, not upon whether the defense independently requested the evidence or could have attempted to locate the witnesses. May relies upon this authority to support his argument that testimony and information relating to Darrell Godfrey and other witnesses would likely have created reasonable doubt had it been disclosed and presented to the jury


Supporting Documents

Original Article

Link to the original article.

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Highlighted Research Copy

Working research copy containing the highlighted passages cited in the Supplemental Motion.

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