People v. Wakefield

No. 107724 (Aug. 15, 2019)

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People v. Wakefield

New York Appellate Division, Third Department
No. 107724 (Aug. 15, 2019)

Facts

A mental-health caseworker performed a welfare check at a man’s apartment and discovered that the man had been strangled with a guitar-amplifier cord. A friend of John Wakefield (defendant) told law-enforcement officers that Wakefield admitted to killing the man. The officers took a cheek swab from Wakefield to compare Wakefield’s DNA to DNA found in the man’s apartment. Officers sent the raw data from the DNA extraction to a company that analyzed the data using TrueAllele software. The TrueAllele test results indicated a high degree of probability that Wakefield’s DNA was on the amplifier cord and on the victim. Wakefield was charged with murder. Before trial, Wakefield moved to exclude the TrueAllele test results, and the trial court held a hearing regarding the results’ admissibility. At the hearing, TrueAllele’s creator testified that although DNA-genotype analysis had traditionally been conducted by humans with some assistance from computers, TrueAllele uses an algorithm to find patterns in DNA data and calculate how much likelier it is that the suspect matches the evidence than a random person. A human analyst inputs commands to tell the computer how to analyze the data using TrueAllele, but the software is designed to incorporate artificial intelligence in the analysis. The TrueAllele software contained roughly 170,000 lines of source code, written by TrueAllele’s creator and developed over 25 versions of the software. The trial court also received evidence that TrueAllele had been evaluated in journals and studies, its high degree of efficacy had been recognized in peer-reviewed publications, it was used by the United States government and several states, including New York, and courts in three other states had admitted TrueAllele test results into evidence. The trial court found that TrueAllele was generally accepted in the scientific community and allowed the evidence. The jury convicted Wakefield, and he appealed to the New York Appellate Division. One of Wakefield’s arguments was that TrueAllele’s source code was the out-of-court declarant of the test results being offered against Wakefield, and Wakefield’s Confrontation Clause rights were violated because he did not have access to the source code.

Rule of Law

Issue

Holding and Reasoning (Pritzker, J.)

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