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Commonwealth v. Rosier

Supreme Judicial Court of Massachusetts
685 N.E.2d 739 (1997)


Facts

The state of Massachusetts (plaintiff) prosecuted Adam Rosier (defendant) for murder. Police identified Rosier as the murderer based on DNA genetic analysis conducted by a reputable laboratory, Cellmark Diagnostics. Cellmark used a relatively new short tandem repeat (STR) technique to spot genetic matches. The accuracy of an STR-identified match depended in part on the laboratory's database, which must have been large enough to ensure statistically valid genetic sampling. Cellmark's STR test found a match between blood and tissue found at the murder scene and samples supplied by Rosier. The trial judge heard Rosier's pretrial motion in limine to exclude the STR test results. Expert witnesses testified the relevant scientific community generally accepts STR as reliable if testing is carried out under proper protocols and the laboratory database can ensure valid sampling. The experts testified Cellmark's testing met those conditions. The judge admitted the STR test results as trial evidence. The jury convicted Rosier. Rosier appealed to the Supreme Judicial Court of Massachusetts, arguing the reliability of STR test results had not been established and therefore the results were inadmissible.

Rule of Law

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Issue

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Holding and Reasoning (Greaney, J.)

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  • A “yes” or “no” answer to the question framed in the issue section;
  • A summary of the majority or plurality opinion, using the CREAC method; and
  • The procedural disposition (e.g. reversed and remanded, affirmed, etc.).

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