In the case of Juan Smith v. Burl Cain, Warden (2011), the United States Supreme Court ruled in favor of Smith, who had been convicted for a 1995 quintuple murder based on a single eyewitness's testimony. The prosecution failed to disclose that the witness initially told police he could not describe the perpetrators due to poor lighting conditions and his own impaired vision from drug use at the time of crime. This violated Brady v. Maryland (1963) which requires prosecutors to share evidence favorable to defendants with their attorneys prior to trial. The court held that this information was material and its omission prejudiced Smith’s defense as it would have allowed him challenge credibility of key witness against him during cross-examination or present an alternative theory about identity of killers.

In the dissenting opinion for Juan Smith v. Burl Cain, Warden, 2011, Justice Clarence Thomas argued that the majority had overstepped its bounds by reevaluating evidence and witness credibility - a role traditionally reserved for juries and trial courts. He contended that there was no clear violation of Brady v. Maryland as claimed by Smith because all material evidence was disclosed to him before his trial; it was just not used effectively in his defense strategy. Furthermore, he believed that even if Larry Boatner (the key eyewitness) had been impeached during cross-examination using undisclosed statements made after the crime occurred, this would not have changed the outcome of Smith's conviction due to other corroborating testimonies and physical evidence linking him to the crime scene.