Stradley Ronon Stevens & Young LLP partner Michael J. Engle (left) and Bruce Murray following Murray's release from Pennsylvania state prison. (Courtesy of Stradley Ronon)
Murray and two co-defendants were convicted of criminal conspiracy, second-degree murder, robbery as a felony of the first degree and possessing an instrument of crime following the December 1980 shooting death of Eric "Kaboobie" DeLegal.
Murray pled not guilty at the time, and maintained his innocence plea through many years of navigating the court system from behind bars.
Documents dating back to the mid-1990s detail Murray's arguments that he was not present at the time of the shooting and reference multiple witness statements corroborating an alibi, in addition to his alleged co-conspirators' statements recanting their trial testimony that Murray had been present that day.
The breakthrough in the case came after Murray spent decades advocating for himself, eventually raising the issue of "actual innocence."
In 2020, U.S. District Judge Anita A. Brody determined that, because of a change in precedent established by the Third Circuit's interpretation of Satterfield v. District Attorney of Philadelphia, Murray was entitled to counsel in order to investigate whether there was an "exceptional circumstance to justify relief." Judge Brody appointed Engle to represent Murray in his 60(b) motion to provide relief from the 1982 judgment.
Speaking to Law360 Thursday, Engle described Murray's "actual innocence" argument, which allows for an exception that reinstates habeas corpus rights to individuals who have been in prison past the statute of limitations on appealing their convictions.
"It's an indication that … not only would there be insufficient evidence to be convicted beyond a reasonable doubt for the crime, but that there's actual information and evidence that points to the fact that the person affirmatively did not commit the crime and was falsely implicated in the crime, and that's what happened here," Engle said.
He added that "multiple witnesses who were coerced into pointing out Mr. Murray as one of the participants in this robbery homicide eventually recanted — credibly recanted — their testimony. And then other evidence came to light: of all kinds of things too numerous to list at the moment."
Those included a police lineup being "mysteriously canceled," in Engle's words, and evidence pointing to the fact Murray could not have been present.
"Murray's wrongful conviction resulted from a myriad of reversible constitutional violations, including the commonwealth's suppression of material exculpatory and impeachment evidence, in violation of Brady v. Maryland ," Engle argued in Murray's 117-page memorandum of law in support of his amended petition for writ of habeas corpus, filed in May.
Judge Brody vacated the sentence and remanded the case to state court, at which point Engle, aided by Stradley Ronon partner Ashley E. Shapiro, successfully advocated for the district attorney's office to withdraw its charges against Murray. Engle and Shapiro are co-chairs of Stradley Ronon's pro bono committee.
All of this information came to light because Engle was able to investigate Philadelphia Police Department homicide files from the time of Murray's arrest, which had been sealed for decades.
"It was the first time any lawyer that had ever represented Bruce Murray had access to all the information in the case, and ultimately, that led us to find that there were numerous pieces of evidence and information that were withheld from the defense," Engle said. "And ultimately, Judge Brody granted the habeas relief on, I believe it was 11 separate Brady violations."
Engle credited a new wave of criminal justice reform with opening the door for Murray to eventually find justice, since the Philadelphia District Attorney's Office under progressive District Attorney Larry Krasner — who defeated an impeachment bid in January — launched a Conviction Integrity Unit to review and overturn wrongful convictions.
That fact was especially poignant for Engle because, he said, his father-in-law, Louis M. Natali, happened to have been Murray's federally appointed lawyer in the late 1990s during an earlier habeas corpus bid.
When asked if he called Natali, who is now retired, to inform him of Murray's release from prison, Engle said yes, and he was "thrilled" to hear it.
"If my father-in-law had been given open access to the homicide file and the DA's file back then, he would have found the things we found and Bruce would have been released from prison back then, potentially," Engle said. "He just sort of finds it incredible that we were able to uncover all of that, but that goes to the fact that this district attorney's office has taken a progressive, open access policy on these cases."
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--Editing by Caitlin Wolper.
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