The First District Court of Appeal held that the failure of the trial court to order a turnover of the photographs that did not match the defendant was not a violation of Brady vs. Maryland, as they did not cast doubt on the State's case. Brady requires that the State disclose any material that could exonerate the defendant, to the defense.
The Court reasoned that there was no reasonable probability that the result of the trial would have been different is the suppressed documents had been disclosed to the defense. The photographs not turned over did not resemble the defendant, and therefore would not have supported his argument that someone else in the photos committed the crime. The conviction was affirmed. Readers who wish to read the complete text of the opinion may access it here. The citation is Willie Allen Lynch v. State of Florida, Case No. 1D16-3290 (Fla. 1st DCA 2018). [There is no Southern Reporter citation available yet].