Jeffrey A. Cookson v. State of Maine, 86 A.3d 1186

Cookson was convicted in 2001 of two counts of intentional or knowing murder and sentenced to two consecutive life terms.
Cookson sought post-conviction DNA testing under 15 M.R.S. §§ 2136-2138 for clothing and other items connected to the case.
The post-conviction court previously denied testing due to concerns about chain of custody and the condition of the evidence.
On remand, the court again denied testing, citing a two-year gap and substantial questions about whether the clothing remained as described and whether it had been substituted or tampered with.
Cookson appealed, arguing the court applied an improper standard and that prima facie evidence for chain of custody was shown.
The majority affirmed, holding that Cookson failed to establish the required prima facie chain of custody under § 2138(4-A)(B).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Cookson met prima facie chain-of-custody	Cookson argues evidence shows lack of substitution and preserved condition.	State contends two-year gap and altered condition defeat prima facie proof.	No; court proper to require prima facie chain-of-custody evidence.
Whether the clothing was the same evidence connected to the murders	Clothing is material and identified as the items buried by Vantol.	Clothing not shown to be the same or in same condition due to degradation and circumstantial gaps.	Clothing established as material but not proven to meet prima facie chain-of-custody.
Standard for prima facie evidence under § 2138(4-A)(B)	Prima facie requires minimal evidence to allow inference, not absolute proof of no tampering.	State contends the court correctly required absence of tampering across the period.	Court erred in elevating proof to negate tampering; prima facie is a low threshold.

Cookson v. State (Cookson II), 2011 ME 53 (Me. 2011) (interprets prima facie evidence for DNA testing and chain of custody)
Cookson, State v. Cookson, 2011 ME 58 (Me. 2011) (defines prima facie evidence standard for DNA testing)
State v. Thibodeau, 358 A.2d 598 (Me.1976) (limits require proof of no tampering at all in chain-of-custody)
State v. Thompson, 503 A.2d 689 (Me.1986) (continuity-of-possession considerations for chain of custody)
State v. Lewis, 401 A.2d 645 (Me.1979) (distinguishes readily identifiable items from fungible evidence in chain of custody)
De Larosa, 450 F.2d 1057 (3d Cir.1971) (admissibility despite not perfect possession history for non-fungible items)
Town of Blue Hill v. Leighton, 2011 ME 103 (Me. 2011) (definition of prima facie evidence in local government context)
Beane, 146 Me. 328 (Me. 1951) (early standard for prima facie evidence concepts)
State v. Ntim, 2013 ME 80 (Me. 2013) (de novo review when underlying facts are undisputed)