On Thursday, December 7, 2023, the District of Columbia Court of Appeals imposed disciplinary sanctions on Mary Chris Dobbie and Reagan Taylor, who were previously assistant U.S. attorneys in the District, for violating their disclosure obligations under Brady v. Maryland during a criminal trial stemming from a jailhouse brawl at the D.C. Jail.
The case is entitled “In the Matter of Mary Chris Dobbie,” with case no. 21-BG-0024.
The charges cited District of Columbia Rules of Professional Conduct 3.8(e), 8.4(c), and 8.4(d), which:
Prohibits prosecutors from intentionally failing to disclose to the defense any evidence or information that the prosecutor knows or reasonably should know tends to negate the guilt of the accused or to mitigate the offense.
Proscribes conduct involving dishonesty, fraud, deceit, or misrepresentation.
Forbids conduct that seriously interferes with the administration of justice.
The Rules of Professional Conduct can be found here.
The case involved prosecutors Mary Chris Dobbie and Reagan Taylor, who were handling the trial of Carl Morton and Alonzo Vaughn for their alleged roles in a fight among inmates at the jail in late 2007. Security camera footage was unclear, so prosecutors relied on testimony from Department of Corrections Lieutenant Angelo Childs to identify the participants.
However, around six months before the 2009 trial, Childs had used excessive force against inmate Ernest Heath during a search, spraying him with chemical agents while Heath’s arms were restrained. An investigation by DOC investigator Benjamin Collins found that Childs had violated use-of-force policies and filed two false reports about the incident – charging Heath with assault and claiming wrongly that Heath was unrestrained and disruptive.
Collins provided his report to Taylor before the trial but did not share the underlying evidence. Supervisors at the U.S. Attorney’s office, including Chief Jeffrey Ragsdale, reviewed the report but concluded the prosecutors could still use Childs, directing them only to “disclose the report and litigate its admissibility.”
Instead of directly turning the report over to the defense, prosecutors Dobbie and Taylor filed it under seal with the court and submitted a motion arguing the defense should not be able to cross-examine Childs about it. The motion did not disclose key conclusions of the Collins Report, including that Childs had filed a false disciplinary report against Heath. It also did not note that Childs had been demoted over the incident.
After Childs testified, the trial judge discovered prosecutors had only submitted a partially redacted version of the Collins Report. The defendants were ultimately convicted, but the D.C. Court of Appeals overturned the conviction of Carl Morton in 2014, finding the prosecutors violated their Brady obligations by not disclosing exculpatory information about Childs.
This led to the filing of disciplinary charges against Dobbie and Taylor. While the Board on Professional Responsibility found violations of Rules 3.8(e), 8.4(c), and 8.4(d) as alleged, it disagreed with the initial recommendation of a 30-day suspension and instead imposed a six-month suspension.
However, in its ruling dated December 7, 2023, the D.C. Court of Appeals agreed there were rule violations but reduced the sanction, imposing a six-month suspension stayed in favor of one-year probation. The court cited inadequate guidance from supervisors and respondents’ otherwise unblemished records in issuing the lesser punishment.
The Disposition states:
“For the foregoing reasons, Mary Chris Dobbie and Reagan Taylor are hereby suspended from the practice of law in the District of Columbia for six months, stayed as to all in favor of a one-year term of probation.”
A copy of the original filing can be found here.
