Fields v. State, 151 Idaho 18

Fields murdered Mary Vanderford in 1988 during a theft at the Wishing Well Gift Shop; he was convicted of felony murder and sentenced to death.
Fields has filed multiple post-conviction petitions; district court repeatedly dismissed without evidentiary hearings.
In 2001 Idaho amended the post-conviction act to allow a limited actual-innocence claim based on fingerprint/DNA results; Fields sought such testing.
DNA testing on the coat failed for lack of sufficient material; hairs on clothing and nail scrapings showed male DNA not from Fields, but no link to the attacker.
Two affidavits from trial witnesses and one from a jail inmate were submitted to support innocence; affidavits described witnesses’ prior identifications and alleged fabrication, but did not connect to Fields.
The district court dismissed Fields’s third post-conviction petition under Idaho Code § 19-4901(a)(6) and the court of appeals affirmed; the Idaho Supreme Court affirms the district court’s ruling.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether district court erred in dismissing under § 19-4901(a)(6)	Fields contends DNA results, viewed with all admissible evidence, could show innocence.	State contends DNA alone does not prove innocence without linking material to the assailant and limits of § 19-2719(5) apply.	No: DNA did not prove innocence; evidence insufficient to meet burden.
Whether affidavits could create a genuine issue of material fact	Affidavits could rebut trial testimony and support innocence.	Affidavits were cumulative/impeaching or untimely under § 19-2719; not sufficient to overcome summary dismissal.	No: affidavits were cumulative/impeaching or outside time limits; no genuine issue.

House v. Bell, 547 U.S. 518 (U.S. 2006) (gateway/holistic standard for innocence claims in federal habeas review; not applicable to state post-conviction)
Schlup v. Delo, 513 U.S. 298 (U.S. 1995) (actual innocence gateway in federal habeas; not applicable to Idaho post-conviction here)
Herrera v. Collins, 506 U.S. 390 (U.S. 1993) (freestanding innocence claim not recognized; limits on innocence showing)
Pizzuto v. State, 134 Idaho 793, 10 P.3d 742 (Idaho 2000) (impeachment/withholding evidence limits in successive petitions)
McCoy v. State, 129 Idaho 70, 921 P.2d 1194 (Idaho 1996) (burden on innocence claim under § 19-4902(f) and preponderance standard)
State v. Harris, 132 Idaho 843, 979 P.2d 1201 (Idaho 1999) (impeaching evidence not automatically admissible to create post-conviction relief)
Nampa & Meridian Irr. Dist. v. Mussell, 139 Idaho 28, 72 P.3d 868 (Idaho 2003) (affirmative standard for sustaining correct theory on appeal)
Stuart v. State, 149 Idaho 35, 232 P.3d 813 (Idaho 2010) (time-bar/waiver considerations for successive petitions)
Lankford v. State, 127 Idaho 100, 897 P.2d 991 (Idaho 1995) (timeliness and waiver principles in post-conviction)