United States District Court for the Eastern District of Pennsylvania
465 F. Supp. 2d 450 (E.D. Pa. 2006)
Lacey Graves (defendant), an African American, was charged with armed robbery. Investigators recovered an umbrella that the perpetrator left at the scene of the crime, as well as shoeprints from shoes the perpetrator was wearing while standing on the bank teller’s counter. Investigators also recovered a DNA sample from a pair of sneakers found at Graves’s girlfriend’s house. The sneakers matched the shoeprints on the counter. Finally, investigators also took a DNA sample from Graves. At trial, the prosecution sought to introduce expert testimony that the DNA from the umbrella and the DNA from the sneakers matched Graves’s DNA. The DNA expert’s report stated that the chance of a random match to the DNA on the umbrella was one in two in the African American population. The report stated that the chance of a random match to the DNA on the left sneaker was 1 in 2900 from the African American population. And the reported stated that the chance of a random match to the DNA on the right sneaker was 1 in 3600 from the African American population. Graves did not argue that the DNA evidence should be excluded under Daubert v. Merrell Dow Pharmaceuticals, 509 U.S. 579 (1993), but rather that the DNA evidence should be excluded under Federal Rule of Evidence (FRE) 403 because given the high probability of a random match, and thus the low statistical significance, the probative value of the DNA evidence was substantially outweighed by its undue prejudice against Graves.
Rule of Law
Holding and Reasoning (DuBois, J.)
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