We will hear argument this morning in case 22-7466, Glossop v. Oklahoma.

Mr. Waxman.

Mr. Chief Justice, and may it please the Court,

Richard Glossop was convicted on the word of one man,

Justin Sneed, the undisputed murderer in this case.

Oklahoma has now disclosed evidence revealing that Mr. Sneed, the undisputed murderer in this case. Oklahoma has now disclosed evidence revealing that

Mr. Sneed lied to the jury about his history of psychiatric treatment, including the fact that a

prison psychiatrist prescribed lithium to treat his previously undiagnosed bipolar disorder.

The prosecution suppressed that evidence and then failed to correct Mr. Sneed's perjured denial,

just as it suppressed evidence that in the middle of trial, in violation of the court's sequestration order,

Sneed altered his testimony about the knife wounds on the victim at the urgent

request of the prosecutor, who then falsely denied to the court her prior knowledge.

There is no adequate or independent jurisdictional bar to review and no warrant for an

evidentiary hearing. As to independence, the Court's opinion is suffused with merits determination on the Brady

and Napu claims, and certainly there is no, quote, clear and express statement that the Court's

decision is based on a bona fide, separate, adequate, and independent grounds

as long required by this Court to preclude review, nor is there any adequate bar.

By rejecting the State's waiver, the Court created a jurisdictional threshold.

It had never applied in any other case.

The disposition was, quote, without support in prior state law, as required by over 60 years of this court's precedent to establish adequacy. No evidentiary hearing could alter the conclusion that Mr. Glossop was denied due process.

There's no dispute that, contrary to Sneed's sworn testimony, the state's own suppressed record shows that he was, in fact, treated by a psychiatrist for bipolar disorder, just as there

is no dispute that Sneed changed his testimony about the knife

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