Hood v. United States
28 A.3d 553
| D.C. | 2011Background
- Hood was convicted of armed first-degree murder and related offenses for a May 18, 1989 attack on 78-year-old Helen Chappelle; the jury found him guilty after trial.
- Two neighbors witnessed Chappelle's cries and a struggle; Hood was seen entering the house and was the last person seen leaving with bloodstained clothing.
- DNA testing of the knife and Hood's clothing initially showed blood but could not identify a donor or time of deposition; testing of other items was not conducted at that time.
- In 2002 Hood filed a pro se motion to vacate convictions, leading to a post-conviction DNA testing plan under the Innocence Protection Act (IPA); only blood-containing items were tested by an independent lab.
- In 2008 the trial court denied Hood's request to test additional items for trace skin cells; Hood appealed the IPA-related denial.
- The court held Hood did not qualify for post-conviction DNA testing of trace skin cells under the IPA's biological-material definition or its materiality standard, and thus did not violate due process by denying that testing.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether trace skin cells qualify as 'biological material' under the IPA | Hood argues trace skin cells are 'biological material'. | United States contends 'biological material' is a defined, seven-category set that does not include nonvisible trace skin cells. | Trace skin cells are not 'biological material' under the IPA. |
| Whether Hood demonstrated materiality to obtain testing | Hood claims testing would produce new evidence exculpating him. | US contends testing would not yield noncumulative evidence of innocence given the record. | Hood failed to show a reasonable probability that testing would reveal exculpatory, noncumulative evidence. |
| Whether the IPA's limitations or the denial of testing violated due process | IPA's limits on testing infringe Hood's liberty interest in innocence relief and due process. | The state may determine procedures for post-conviction relief; denial did not violate due process because materiality was not shown. | No due process violation; IPA procedures, including the materiality requirement, were satisfied. |
Key Cases Cited
- Veney v. United States, 929 A.2d 448 (D.C. 2007) (definition and scope of 'biological material' and post-conviction testing under IPA)
- Osborne v. Dist. Atty's Office for the Third Judicial Dist., 129 S. Ct. 2308 (Supreme Court 2009) (procedural flexibility in post-conviction relief; materiality standard)
- Harvey v. Horan, 285 F.3d 298 (4th Cir. 2002) (DNA testing of degraded samples; supports use of STR analysis on challenging evidence)
- United States v. Fasano, 577 F.3d 572 (5th Cir. 2009) (ordering DNA testing of epithelial cells when relevant to identity)