Powers v. State
2011 Tenn. LEXIS 595
| Tenn. | 2011Background
- Powers was convicted in separate trials of aggravated rape (1980) and aggravated rape and robbery with a deadly weapon (1980).
- In 2007, Powers petitioned under the Post-Conviction DNA Analysis Act to analyze V.B.'s underwear for DNA exculpatory value.
- The post-conviction court denied relief; the Court of Criminal Appeals affirmed, limiting testing to petitioner's DNA versus trial evidence DNA.
- The Tennessee Supreme Court granted review to determine if the Act permits DNA database matches to satisfy the burden and if the Court of Criminal Appeals’ interpretation obstructs actual innocence.
- The Court held the Act permits access to a DNA database if a database match would create a reasonable probability the petitioner would not have been prosecuted or convicted, or would have had a more favorable outcome.
- The judgment of the Court of Criminal Appeals is reversed and the case remanded for entry of an order granting DNA analysis.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Does the Act permit database hits to satisfy testing burden? | Powers argues database matches are within the Act’s scope. | State contends testing limited to comparison with crime-scene samples, not database hits. | Yes; Act permits database comparisons to satisfy the burden. |
| Can database-directed results prove actual innocence under the Act? | Exculpatory results could demonstrate innocence via database hits. | Evidence and identifications would still support conviction regardless of hits. | Yes; results that undermine confidence could exonerate or reduce culpability. |
| Must four criteria of 40-30-304 be met for mandatory testing? | All four criteria can be satisfied even with long delay and potential third-party DNA. | The State argues the first criterion is not met here due to overwhelming trial evidence. | All four criteria can be satisfied; testing ordered. |
| Is the statutory definition of DNA analysis broad enough to include database comparisons? | Text supports broader interpretation to advance exoneration and justice. | Court should adhere to narrow reading focusing on time-of-offense samples. | Broad interpretation permitted; DNA databases contemplated. |
| Does legislative history support using DNA databases for third-party guilt identification? | Sponsors intended both exoneration and identification of true perpetrators via databases. | History emphasizes testing against crime-scene DNA, not third-party hits. | Legislative history supports database usage to identify true perpetrators. |
Key Cases Cited
- Powers v. State, notable cited in text (Tenn. 2011) (Tenn. 2011) (treats Post-Conviction DNA Analysis Act interpretation)
- State v. Scarborough, 201 S.W.3d 607 (Tenn. 2006) (DNA database context and purposes of DNA statutes)
- Griffin v. State, 182 S.W.3d 795 (Tenn. 2006) (statutory interpretation guiding testing eligibility)
- Banks v. United States, 490 F.3d 1178 (10th Cir. 2007) (support for exoneration and solving crimes via CODIS-like databases)