State v. Pratt

In 1975, Appellant was convicted of sodomy, forcible rape, and robbery. In 2004, Appellant moved for testing under the DNA Testing Act (“Act”) of the biological evidence pertinent to his conviction. The district court granted the motion. The next year, DNA testing revealed that at least one stain of biological material was from a male who was not Appellant. The district court denied Appellant’s subsequent motion to vacate his convictions or grant a new trial, holding that the DNA test results were neither exonerating nor exculpatory because, among other things, the testing could not distinguish between semen and epithelial cells in older materials. In 2011, Appellant filed a second motion for DNA testing of the biological materials on the victims’ shirts, alleging that new more accurate testing techniques could lead to exonerating or exculpatory evidence, particularly because restesting could distinguish between semen and epithelial cells on the materials. The district court denied the motion. The court of appeals reversed. The Supreme Court affirmed, holding that the district court erred in denying Appellant’s motion for resting under the Act, as, “[i]ndisputably, the requested retesting ‘may’ lead to exculpatory evidence.” View "State v. Pratt" on Justia Law