Glendale More Jr. v. State of Iowa, 2016 Iowa Sup. LEXIS 60

Glendale More Jr. was convicted of first-degree murder in 1984 for the killing of Wauneita Townsend; prosecution relied in part on FBI Compositional Bullet Lead Analysis (CBLA) linking crime-scene bullets to a cartridge found in More’s pocket.
At trial the defense presented chemist Steven Morris to challenge CBLA’s interpretive reliability; the jury nonetheless returned a guilty verdict amid substantial circumstantial evidence (fingerprints, eyewitness Elmore, insurance motive, flight, cartridge found on More).
Decades later scientific critiques (notably the National Research Council report) and an April 2009 FBI letter disavowing certain CBLA interpretive claims showed the FBI’s trial testimony overstated what CBLA could reliably prove.
More filed a second postconviction-relief petition (2007) arguing the changed CBLA science was newly discovered evidence and that admission of CBLA violated due process; the district court and Iowa Court of Appeals denied relief.
The Iowa Supreme Court granted review and affirmed denial of postconviction relief, concluding (a) the FBI letter/new science qualified as newly discovered evidence but More failed to show a reasonable probability the verdict would have been different, and (b) CBLA testimony, while flawed, did not render the trial fundamentally unfair in light of cross‑examination, defense expert testimony, and the weight of other evidence.

Issue	Plaintiff's Argument (More)	Defendant's Argument (State)	Held
Whether newly discovered scientific developments discrediting CBLA require a new trial	CBLA has been discredited (FBI letter, NRC) and the FBI’s trial testimony implying a box‑level match was false; this is newly discovered, noncumulative evidence that probably would have changed the verdict	Even excluding CBLA, the record contains strong circumstantial evidence (fingerprints, eyewitness, cartridge on More, flight, motive); More cannot show a reasonable probability of a different result	Court: FBI letter/new science is newly discovered but More failed the high burden to show the verdict probably would have differed; no new trial granted
Whether admission of CBLA testimony violated due process	Admission of scientifically invalid or misleading CBLA testimony deprived More of a fundamentally fair trial	CBLA testimony was challenged at trial, defense cross‑examined FBI witness and presented its own expert; any shortcomings could be weighed by the jury and did not render the trial fundamentally unfair	Court: No due process violation — CBLA, though flawed and later disavowed, was not so inherently unreliable that allowing the jury to consider it made the trial fundamentally unfair

State v. Behn, 868 A.2d 329 (N.J. Super. Ct. App. Div. 2005) (granting new trial where post‑trial scientific evidence undermined FBI CBLA testimony and could have changed verdict)
Commonwealth v. Lykus, 885 N.E.2d 769 (Mass. 2008) (denying new trial where FBI testimony was adequately impeached at trial and prosecutor did not rely on CBLA as pivotal)
Ragland v. Commonwealth, 191 S.W.3d 569 (Ky. 2006) (excluding CBLA testimony under Daubert on direct review given scientific critiques, NRC report, and FBI change in position)
St. Clair v. Commonwealth, 451 S.W.3d 597 (Ky. 2014) (denying collateral relief despite CBLA now being inadmissible because other trial evidence rendered a different result improbable)
United States v. Berry, 624 F.3d 1031 (9th Cir. 2010) (rejecting due process challenge to CBLA where testimony was not so arbitrary as to render trial fundamentally unfair)
Manson v. Brathwaite, 432 U.S. 98 (1977) (due process requires exclusion only when evidence is so unreliable that its admission makes the trial fundamentally unfair)
Strickland v. Washington, 466 U.S. 668 (1984) (standard referenced for prejudice analysis distinctions though not the controlling test here)