Haddock v. State
286 P.3d 837
| Kan. | 2012Background
- Postconviction DNA testing under K.S.A. 21-2512 was allowed; results were mixed (favorable, corroborating, and inconclusive).
- District court denied Haddock’s motions for new trial; on appeal, the Kansas Supreme Court previously remanded for further procedures and consideration of the full record.
- Evidence at trial included orchestrated crime scene, blood and spatter patterns, hair clutched in Barbara Haddock’s hand, and DNA on clothing/shoes; older hair DNA suggested Haddock’s guilt, while newer testing introduced potential third-party DNA.
- Haddock moved for DNA testing in two stages (first motion: hair/eyeglasses/fingernail scrapings; second motion: shoes/shirt/pants) and later proceeded to consumption testing on remaining clothing.
- On remand, enhanced STR testing on the shoes and shirt suggested Barbara as major donor with possible minor donor contribution; district court nonetheless found no reasonable probability of a different outcome at trial and denied relief, which the court of appeals affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether favorable postconviction DNA results require a new trial | Haddock contends favorable results mandate relief. | State argues relief depends on materiality, not automatic exoneration. | No automatic new trial; materiality and probability of different outcome control. |
| Whether the district court followed the remand mandate from Haddock II | Haddock asserts district court applied exoneration standard contrary to remand. | State contends court applied proper standard and considered all evidence. | District court complied with remand and applied the applicable materiality standard. |
| The proper standard of review and materiality for postconviction DNA testing | Haddock argues abuse-of-discretion review for favorable evidence, de novo for materiality. | State argues three-part abuse-of-discretion standard; materiality reviewed de novo. | Materiality reviewed de novo; favorable/unfavorable determinations reviewed for abuse of discretion, with deference to factual findings. |
| Whether the new DNA evidence could have changed the verdict | New hair DNA and other results undermine the trial themes and could create reasonable doubt. | Overall evidence still points to Haddock; new DNA does not create reasonable probability of different verdict. | No reasonable probability that the new DNA evidence would change the jury’s verdict. |
| Impact of third-party DNA on trial themes and likelihood of retrial | Presence of non-Haddock DNA on hair/glasses could support a third-party theory. | Other evidence remains strongly against a different conclusion; hair DNA not dispositive. | Holistic review shows combined evidence still insufficient to warrant a new trial. |
Key Cases Cited
- State v. Haddock, 282 Kan. 475, 282 Kan. 475 ((2006)) (remand and evaluation of favorable DNA evidence for new trial)
- Buckman v. State, 267 Neb. 505 ((2004)) (DNA may be probative without being exculpatory; not strictly exonerating)
- Goldsmith v. State, 292 Kan. 398 ((2011)) (statutory interpretation; standards for 21-2512 review)
- House v. Bell, 547 U.S. 518 ((2006)) (holistic review of all evidence for probable effect on jurors)
- Osborne v. District Attorney for Third Judicial Dist., 557 U.S. 52 ((2009)) (Brady framework not controlling postconviction DNA relief in all contexts)
- Denney v. State, 283 Kan. 781 ((2007)) (requires hearing when DNA testing results are favorable)
- Adams v. State, 280 Kan. 494 ((2005)) (standard of review for new-trial determinations)
- Ward v. State, 292 Kan. 541 ((2011)) (three-part abuse-of-discretion framework for review)
- Warrior v. State, 294 Kan. 484 ((2012)) (Brady/House guidance applied to postconviction DNA)
- Thomas v. State, 257 Kan. 228 ((1995)) (burden on non-dispositive new-evidence motions)