Cookson v. State
17 A.3d 1208
| Me. | 2011Background
- Cookson was convicted in 2002 of two counts of knowing and intentional murder and sentenced to two consecutive life terms.
- During trial, a witness, David Vantol, privately confessed to the murders to Cookson's counsel and investigators, and later led police to the murder weapon.
- Vantol also claimed to have worn clothing at the time; he later recanted, alleging the clothing items were unrelated and obtained from a junk car.
- Cookson sought DNA testing of the clothing and other items under 15 M.R.S. §§ 2137, 2138; the superior court denied most requests.
- The appellate court granted a certificate of probable cause to appeal and vacated the denial, remanding for findings under 15 M.R.S. § 2138(5).
- The Supreme Judicial Court held that the record requires findings on all five prima facie criteria, and clarified the meaning and temporal scope of chain of custody in this context.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the court properly ordered DNA analysis under § 2138(4-A) based on prima facie chain of custody. | Cookson contends there was prima facie chain of custody and lack of tampering. | State argues chain of custody was insufficient and timing weakened reliability. | Court vacated and remanded for determinations on all five criteria. |
| Whether the temporal scope of chain of custody includes pre-police possession period. | Cookson asserts pre-possession period should count to secure custody. | State contends custody starts when police take possession; not all pre-possession time is relevant. | Temporal scope expands to include pre-possession period; remand required to assess impact. |
Key Cases Cited
- State v. Aboda, 2010 ME 125 (Me. 2010) (guides interpretation of the DNA testing statute)
- James v. State, 2008 ME 122 (Me. 2008) (sets prima facie standard for DNA motion under § 2138)
- Skinner v. Switzer, 131 S. Ct. 1289 (S. Ct. 2011) (post-conviction DNA relief analysis with legitimate chain-of-custody considerations)
- State v. Lobozzo, 1998 ME 228 (Me. 1998) (chain of custody considerations in Maine)
- State v. Morris, 440 A.2d 1035 (Me. 1982) (impact of missing time on chain of custody; weight not admissibility)
- State v. Lagasse, 410 A.2d 537 (Me. 1980) (prior custody events used to establish chain of custody)
- Gallego v. United States, 276 F.2d 914 (9th Cir. 1960) (early articulation of chain of custody factors)