Reed, Rodney, AP-77,054

Rodney Reed seeks post-conviction DNA testing under Article 64.01/64.03 in an ongoing capital appeal.
The District Court denied Reed’s Chapter 64 motion, including the exculpatory-results inquiry and delay elements.
Reed moved for testing on multiple items alleged to contain DNA connected to the crime and the perpetrator.
The State opposed testing and urged a narrow interpretation of exculpatory results and delay.
The State sought expedited consideration to preserve an imminent execution; the court granted a stay pending innocence claims.
Reed’s brief argues testing could show third-party DNA and other exculpatory results, potentially exonerating him.

Issue	Plaintiff's Argument	Defendant's Argument	Held
proper exculpatory results standard	Reed contends the standard should consider all realistically possible exculpatory results, including third‑party DNA.	Reed's position is that the district court misinterpreted exculpatory results as limited to defendant exclusion.	exculpatory results must include realistic, non-exclusion possibilities
effect of exculpatory results on acquittal	Reed showed the district court failed to assess how exculpatory results could change trial outcomes.	State maintains the district court appropriately limited its assessment to the items' impact on guilt.	district court erred by not applying proper exculpatory-result presumption
unreasonable delay standard	Reed did not file to delay execution; the stay and long history show no intent to delay unreasonably.	State argues the delay standard should be highly deference-based due to credibility findings.	court should apply de novo review and Reed did not delay unreasonably
chain of custody and biological evidence	Reed proved chain of custody and that tested items contain biological material suitable for testing.	State disputes chain of custody implications and materiality of biological evidence on certain items.	Reed established proper chain of custody and presence of biological material

Routier v. State, 273 S.W.3d 241 (Tex. Crim. App. 2008) (recognizes consideration of third-party DNA and exculpatory results)
Ex parte Miles, 359 S.W.3d 647 (Tex. Crim. App. 2012) (exculpatory evidence includes broader DNA implications and investigative leads)
Ex parte Reed, 271 S.W.3d 698 (Tex. Crim. App. 2008) (post-conviction DNA testing considerations)
Holberg v. State, 425 S.W.3d 282 (Tex. Crim. App. 2014) (distinguishes contexts of DNA testing and biological material)
State v. Swearingen, 424 S.W.3d 32 (Tex. Crim. App. 2014) (discusses scope of exculpatory results and DNA testing)
House v. Bell, 547 U.S. 518 (U.S. Supreme Court 2006) (context for Brady-like relevance of undiscovered evidence)
Dinkins v. State, 84 S.W.3d 639 (Tex. Crim. App. 2002) (discusses specificity and evidence requirements in DNA motions)