Jamison v. State
148 A.3d 1267
Md.2016Background
- William Todd Jamison entered an Alford plea in 1990 to first-degree rape and kidnapping and was sentenced to life plus 30 years.
- In 2008 Jamison petitioned under Md. Code, Crim. Proc. § 8-201 for post-conviction DNA testing of slides taken from the victim; the trial court ordered testing and Cellmark performed the tests.
- Jamison moved to vacate his conviction and sought a writ of actual innocence under § 8-301 after receiving DNA results; the State opposed on the merits and argued the guilty plea barred relief.
- The Circuit Court denied relief; Jamison appealed raising multiple challenges including statutory scope, reliability of testing, and whether non-matching DNA is favorable.
- The Court of Appeals held that a defendant who pled guilty (including by Alford plea) cannot obtain post-conviction DNA testing under § 8-201 because the statute’s post-result standard requires comparing trial evidence to newly discovered evidence and thus presumes a conviction after trial.
Issues
| Issue | Plaintiff's Argument (Jamison) | Defendant's Argument (State) | Held |
|---|---|---|---|
| Whether a person who pled guilty may seek post-conviction DNA testing under § 8-201 | § 8-201 is silent on pleas; legislative changes removed an "identity" requirement and thus permit plea-based petitions | Statute requires a showing that the DNA would have affected a trial verdict; that comparison requires an actual trial, so plea convictions are excluded | A guilty plea (including Alford plea) bars relief under § 8-201; affirmed |
| Standard applied after favorable DNA ("substantial possibility" that petitioner would not have been convicted) — applicability to guilty pleas | The evaluative standard can be applied to guilty pleas (or Alford pleas); DNA proceedings could serve as an evaluative record | The statutory standard contemplates comparison to a trial record; where no trial occurred the required weighing cannot be performed | The "substantial possibility" standard presumes a trial record and thus cannot be applied to plea convictions |
| Reliability/admissibility of Cellmark DNA testing and expert probabilistic genotyping | Cellmark results and probabilistic genotyping by Jamison's expert were reliable and favorable; non-matching donor DNA is exculpatory | State challenged reliability and general acceptance of methods; even reliable results would not overcome plea-based conviction | Court did not reach merits because plea-bar foreclosed § 8-201 relief; Circuit Court’s merits rulings were not adopted as the basis for the decision |
| Whether DNA that matches neither victim nor defendant is "favorable" and creates a substantial possibility of different result | Non-matching DNA pointing to another source is favorable and could have produced a different outcome | Even favorable results cannot be weighed against a non-existent trial record after a plea | Such favorable-effect inquiry requires comparing to trial evidence; unavailable after a plea, so statutory remedy is not available |
Key Cases Cited
- Bishop v. State, 417 Md. 1 (Md. 2010) (Alford plea is the functional equivalent of a guilty plea for many procedural purposes)
- Yonga v. State, 446 Md. 183 (Md. 2016) (writ-of-actual-innocence standard requires comparison to a trial record; relief unavailable after guilty plea)
- North Carolina v. Alford, 400 U.S. 25 (U.S. 1970) (defendant may plead guilty while maintaining innocence if plea is voluntary and supported by a factual basis)
- Strickland v. Washington, 466 U.S. 668 (U.S. 1984) (ineffective assistance standard: performance and prejudice/prong of reasonable probability)
- Jackson v. State, 448 Md. 387 (Md. 2016) (affirming denial of new trial under § 8-201 where defendant entered an Alford plea)
- Rudman v. State Board of Physicians, 414 Md. 243 (Md. 2010) (Alford plea may not produce same collateral consequences as an explicit admission of guilt)