Brady Violation-Evidence Suppression

WI Court of Appeals – District I

Case Name: State of Wisconsin v. Ruthes Chester Holeyfield

Case No.: 2025AP001657-CR

Officials: Donald, C.J., Colón, P.J., and Geenen, J.

Focus: Brady Violation-Evidence Suppression

Holeyfield was convicted of repeated sexual assault of a child. His postconviction motion for a new trial was denied.

Holeyfield then argued that the State violated Brady v. Maryland by failing to disclose forensic interviews of the victim’s siblings, Kalen and Ayla. The State conceded that the interviews had been inadvertently suppressed and appeared to concede that portions of Kalen’s interview could constitute favorable impeachment evidence.

The Court of Appeals nevertheless held that there was no Brady violation because the evidence was not material. Under Brady, suppressed evidence is material only if there is a reasonable probability that disclosure would have produced a different trial result.

The court concluded that the siblings’ statements did not materially contradict the victim’s account that she was alone with Holeyfield in the basement during the assaults. Kalen’s statements were somewhat contradictory and reflected uncertainty about whether the victim was telling the truth. Ayla’s statements similarly did not establish that the assaults could not have occurred. Kalen’s statement that the victim had once asked to live with Holeyfield also did not outweigh the substantial evidence supporting the victim’s credibility.

The court emphasized the victim’s detailed forensic interview, her emotional and reluctant discussion of the abuse, her explanation for delayed disclosure, and the absence of an apparent motive to fabricate.

Affirmed.

Decided 08/11/26

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