Hall v. State, 2013 Ark. 506

Rammie Earl Hall was convicted of capital murder in 1992 and sentenced to life without parole; this Court affirmed on direct appeal.
In 2011 Hall filed a pro se petition under Act 1780 (Ark. Code §§ 16-112-201 to -208) seeking DNA testing of a cigarette butt found at the victim’s home.
Hall argued improved DNA technology could exclude him as the source of the biological material or match another offender.
The trial court denied testing, finding even a match to another person would not exonerate Hall because anyone could have left the cigarette in the house.
The crime-lab report from the original investigation found no amylase (saliva) or blood on the cigarette butt; investigators testified neither Hall nor the victim smoked and the home had not been cleaned so the butt’s age was unknown.

Issue	Hall's Argument	State's Argument	Held
Whether Hall is entitled to postconviction DNA testing under Act 1780	Advanced DNA methods could test the cigarette butt and produce new material evidence raising a reasonable probability Hall did not commit the murder	Even if testing produced a profile, it would not exonerate Hall because the cigarette could have been left by anyone; the existing lab found no saliva for testing	Denied — Hall failed to show testing would produce new material evidence or raise a reasonable probability of innocence

Hall v. State, 315 Ark. 385, 868 S.W.2d 453 (affirming Hall’s 1992 conviction)
Douthitt v. State, 366 Ark. 579, 237 S.W.3d 76 (2006) (describes predicate requirements for postconviction DNA testing)
Whitfield v. State, 346 Ark. 43, 56 S.W.3d 357 (2001) (addresses admissibility of DNA evidence)
Echols v. State, 2010 Ark. 417, 373 S.W.3d 892 (distinguishing postconviction testing outcomes that can support a new-trial motion)
Aaron v. State, 2010 Ark. 479 (discusses availability and admissibility of DNA evidence in Arkansas)

Appeal dismissed; motion for extension of time to file brief rendered moot.