Echols v. State, 2010 Ark. 417

Echols, condemned to death in 1994 for triple capital murder in West Memphis; case involves the Robin Hood woods murders and DNA evidence.”,

Issue	Plaintiff's Argument	Defendant's Argument	Held
Statutory interpretation of 16-112-208(b) and application to prior testing	Echols argues 208(b) governs only current testing under 202 and the prior testing should not be governed by the new standard.	State contends 208(b) applies and testing is subject to the newer standards, including the standard of inconclusiveness.	208(b) inapplicable to the testing ordered under the prior statute; circuit court erred in applying 208(b)
How 208(e) should weigh DNA results with all other evidence	Evidence from DNA should be weighed with all case evidence, regardless of trial introduction.	State argues DNA results should be weighed against all other guilt evidence, not solely the DNA.	All other evidence means all relevant evidence; court erred in weighing DNA results only against guilt evidence
Standard for compelling innocence under 208(e)(3)	Echols need only show compelling evidence that a new trial would acquit.	State contends a stringent, possibly dispositive showing is required.	Standard requires establishing by compelling evidence that a new trial would result in acquittal, not a required conclusive innocence finding
Right to an evidentiary hearing under 16-112-205	A hearing was required before ruling on the motion.	The circuit court did not need a hearing if petition conclusively shows no relief.	Circuit court erred by denying an evidentiary hearing; remand for an evidentiary hearing

Greene v. State, 356 Ark. 59, 146 S.W.3d 871 (2004) (statutory interpretation standard and review)
Singleton v. State, 2009 Ark. 594, 357 S.W.3d 891 (2009) (de novo review on statutory interpretation)
House v. Bell, 547 U.S. 518, 126 S.Ct. 2064, 165 L.Ed.2d 1 (2006) (federal standard cited for comparison to Arkansas statute)