Phillips v. State
152 A.3d 712
| Md. | 2017Background
- Richmond Phillips was convicted (jury trial Jan. 2013) of two first‑degree murders; DNA testing (buccal swab and steering‑wheel sample) by the Prince George’s County lab linked Phillips to a mixed profile; lab reported validation "according to the FBI’s Quality Assurance Standards (QAS)."
- Phillips moved in limine to exclude DNA evidence, arguing the lab’s methods for complex, low‑template DNA were not generally accepted (Frye‑Reed); State invoked Maryland’s DNA admissibility statute (CJP § 10‑915) to admit the DNA without a Frye hearing.
- The trial court held the lab’s validation statement did not satisfy § 10‑915 (because TWGDAM/DNA Advisory Board no longer existed) and held a Frye‑Reed hearing; after that hearing it admitted the evidence under Frye‑Reed. Phillips was convicted and sentenced; the Court of Special Appeals affirmed.
- The Court of Appeals granted certiorari on whether the DNA was admissible under Frye‑Reed (Phillips) and, conditionally, whether the lower courts erred in ruling § 10‑915 did not permit automatic admissibility based on the lab’s QAS validation (State’s cross‑petition).
- The General Assembly amended § 10‑915 in 2016 to reference the QAS prospectively; the Court of Appeals held the case was not moot because the prior statute governed events at trial and an effective remedy remained available.
- Holding: the Court ruled the lab’s QAS validation statement satisfied the pre‑2016 § 10‑915(b) requirement, so the DNA was automatically admissible and the Frye‑Reed hearing was unnecessary (error to hold one was harmless); the Court affirmed the Court of Special Appeals’ judgment.
Issues
| Issue | Plaintiff's Argument (Phillips) | Defendant's Argument (State) | Held |
|---|---|---|---|
| Whether the case is moot after 2016 amendment to § 10‑915 | Amendment makes issue academic; dismiss cross‑petition as moot | Not moot because prior statute controlled at trial and decision affects other pending cases | Not moot — prior statute applies to events here and Court can grant effective relief |
| Whether the lab’s QAS validation satisfies pre‑2016 CJP § 10‑915(b) | Invalid: § 10‑915 requires validation by standards "established by TWGDAM or the DNA Advisory Board," which no longer existed; QAS (and SWGDAM) are distinct | Valid: QAS are the Quality Assurance Standards established by the DNA Advisory Board and thus satisfy § 10‑915(b) | Held valid: QAS are "standards established by the DNA Advisory Board," so the lab’s statement met § 10‑915(b) |
| Whether compliance with QAS is sufficient when QAS lack specific guidance for complex, low‑template mixtures | Insufficient: QAS do not address complex low‑template mixtures; SWGDAM guidance is more current and rigorous | Sufficient: § 10‑915 is a minimum‑requirements statute; compliance with FBI QAS suffices for automatic admissibility; challenges go to weight, not admissibility | Held: QAS compliance is sufficient for automatic admissibility under § 10‑915; lack of specific QAS guidance may affect weight, not admissibility |
| Whether a Frye‑Reed hearing was required before admitting DNA evidence | Frye‑Reed required because lab methods for complex mixtures lack general acceptance | Not required if § 10‑915(b) is satisfied by the lab’s QAS validation statement | Held: Frye‑Reed hearing unnecessary because § 10‑915(b) was satisfied; trial court’s Frye hearing was error but harmless here |
Key Cases Cited
- Armstead v. State, 342 Md. 38 (Court's discussion of statutory automatic admissibility vs. Frye‑Reed)
- Reed v. State, 283 Md. 374 (defines Maryland’s Frye‑Reed general‑acceptance test)
- Frye v. United States, 293 F. 1013 (establishes Frye general‑acceptance rule)
- Bottini v. Dep’t of Fin., 450 Md. 177 (standard for reviewing trial court factual findings)
- Breeding v. Koste, 443 Md. 15 (deference to trial court factual findings)
- Green v. Nassif, 401 Md. 649 (mootness and ability to fashion effective remedy)
- Douglas v. State, 423 Md. 156 (statutory‑interpretation principles)