Miller v. Pate

Lloyd Miller (defendant) was charged with the sexual attack and murder of eight-year-old Janice May in 1955. No eyewitnesses testified at trial. The prosecution produced a pair of underwear shorts as a key piece of trial evidence. Police claimed that they found the shorts three days after May’s murder in an abandoned building a mile away from the crime scene. A chemist testified that the shorts were stained with type-A blood. Throughout the trial, witnesses and attorneys referred to the shorts as bloody or blood-stained. In closing arguments, the prosecution emphasized that the blood on the shorts was May’s type-A blood—not Miller’s type-O blood. Miller was convicted and sentenced to death. The Illinois Supreme Court affirmed the death sentence. Miller filed a federal habeas petition, and the federal district court ordered the government to present the shorts so that Miller could test them. At Miller’s evidentiary hearing, a chemical microanalyst testified that although the shorts’ reddish-brown stains would appear to be blood to a layperson, testing had revealed that the stains were a pigment used in paint; there were no traces of blood on the shorts. The microanalyst acknowledged that it was impossible to be absolutely certain that the shorts had never had blood on them. The trial prosecutor admitted that he knew at trial that the shorts were stained with paint and that police had written a memorandum explaining the paint. The government claimed that blood stains had existed at trial but disappeared over time and that the paint stains were so obvious to anyone who saw the shorts at trial that it was unnecessary for the prosecution to reference the paint stains. The district court granted habeas relief, but the appellate court reversed. The United States Supreme Court granted certiorari.