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United States v. Brown

557 F.2d 541 (1977)

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United States v. Brown

United States Court of Appeals for the Sixth Circuit

557 F.2d 541 (1977)

Facts

A clinic of the Planned Parenthood Association was firebombed. Hayward Leslie Brown (defendant), a Black man from Detroit, was apprehended near the clinic by the police. Also, the police discovered hair of unknown origin at the clinic. After Brown confessed to the firebombing, charges were filed against him. Later, a hair sample was taken from Brown. At the trial, Michael Bayard and Dr. Robert Muggli testified as expert witnesses. Bayard and Muggli used a procedure called ion microprobic analysis to compare hair samples. Ion microprobic analysis measured the trace-element content of a hair sample. Bayard and Muggli had a test group containing 130 hair samples. The samples in the test group were collected primarily from White people who lived in Chicago. Bayard and Muggli conducted ion microprobic analysis on the unknown hair and Brown’s hair. The analysis produced charts that showed the trace elements in these samples. The charts from the samples were then compared to the charts from the samples in the test group. Based on this comparison, Bayard and Muggli determined that Brown was the source of the unknown hair. The district-court judge admitted evidence of the ion microprobic analysis conducted by Bayard and Muggli. Subsequently, Brown was convicted. Brown appealed.

Rule of Law

Issue

Holding and Reasoning (Celebrezze, J.)

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