context: Without Williams's statement, the defendant was denied a "substantial factual basis for contending to the jury that [a witness] misidentified him." The Commonwealth should have done the same once it had been put on actual notice by defense counsel of the request for specific favorable evidence.
citation_a.signal: cf.
citation_a.identifier: 396 Mass. 590, 596-599
citation_a.parenthetical: in some circumstances, prosecutor "should be required to seek access to material and exculpatory evidence" not in possession of prosecutor or police
citation_a.sentence: Cf. Commonwealth v. Donahue, 396 Mass. 590, 596-599 (1986) (in some circumstances, prosecutor “should be required to seek access to material and exculpatory evidence” not in possession of prosecutor or police).
citation_b.signal: see also
citation_b.identifier: 514 U.S. 419, 437
citation_b.parenthetical: "the individual prosecutor has a duty to learn of any favorable evidence known to the others acting on the government's behalf in the case, including the police"
citation_b.sentence: See also Kyles v. Whitley, 514 U.S. 419, 437 (1995) (“the individual prosecutor has a duty to learn of any favorable evidence known to the others acting on the government’s behalf in the case, including the police”).