U.S. Supreme Court Update: McDaniel v. Brown

A Service from the ABA Criminal Justice Section, http://www.abanet.org/crimjust

The U.S. Supreme Court has ruled against a defendant convicted of the rape of a 9-year-old girl after a night of heavy drinking.

The Supreme Court said in a per curiam opinion that overstated estimates of a DNA match at trial did not warrant reversal of a conviction when there is still “convincing evidence of guilt.”

The defendant, Troy Brown, had alleged on appeal that the state mischaracterized the probability that his DNA matched that of someone in the general population. He also claimed that a prosecution expert had misstated the chances of a DNA match between himself and his two brothers. All three lived near the victim.

“DNA evidence remains powerful inculpatory evidence even though the state concedes [its expert] overstated its probative value,” the Supreme Court wrote in McDaniel v. Brown.

The court remanded for consideration of Brown’s claims of ineffective assistance.

The court had granted cert in the case last January, SCOTUSblog reports. Oral arguments set for October were later canceled by the court.

According to SCOTUSblog, the decision was “based mainly on a legal ground that neither side in the case believed remained in issue-the sufficiency of the DNA evidence, under Jackson v. Virginia.”

According to the opinion, the court had granted cert to consider two issues: the proper standard of review for a Jackson claim, and whether such a claim may rely upon evidence outside the trial record that goes to the reliability of trial evidence.


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