People v. Reeves
California Court of Appeal
109 Cal. Rptr. 2d 728 (2001)

- Written by Joe Cox, JD
Facts
[Editor’s Note: This brief is based on combined information from pages 188 and 213 in the casebook to provide comprehensive details.] Lawrence Reeves (defendant) was tried and convicted of several burglaries and sex crimes by the State of California (plaintiff). Reeves had been sentenced to 77 years in prison. In his trial, Reeves was identified as the likely perpetrator of the sex crimes based on two different forms of DNA evidence. Reeves appealed his conviction, challenging the admission of DNA evidence on several bases. Among the evidence entered against Reeves was restriction fragment length polymorphism (RFLP) analysis. RFLP evidence involved taking a DNA sample from the suspect and using restriction enzymes to cut the DNA into fragments, which ultimately translated into autorads, an x-ray film showing the DNA fragments. Any mismatch disqualified the suspect as the DNA source. The second form of evidence used was polymerase chain reaction, which created a genetic photocopy and was ideal for situations in which the DNA sample available was too small or degraded to make the RFLP analysis useful. In this test, similar profiles then required consideration of how common such profiles would be in the general population. Reeves took issue with the DNA evidence being offered with the claim that the chance of a random match between the suspect’s DNA and the sample taken was one in millions or billions, without any indication of a laboratory error rate. One defense expert had defined the possibility of a laboratory error rate as between one in hundreds and one in thousands—much lower than the random-match rates offered in evidence.
Rule of Law
Issue
Holding and Reasoning (Parrilli, J.)
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