State v. Bolden
108 So. 3d 1159
La.2012Background
- Convictions and sentences on two counts of aggravated rape (La.R.S. 14:42).
- Court of Appeal reversed, finding Confrontation Clause error from DNA expert testimony.
- Victims’ DNA samples tested ~10 years earlier by two labs; reports not introduced under La.R.S. 15:499.
- DNA profiles compared to defendant’s profile; samples later linked to defendant via CODIS.
- Appeal held that without DNA testimony, evidence insufficient; ordered discharge.
- Louisiana Supreme Court reverses, reinstates convictions and sentences.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether there was Confrontation Clause error | Bolden argues DNA testimony violated Confrontation Clause. | Bolden contends error warranted reversal. | No Confrontation Clause error under Williams framework. |
| Sufficiency of the evidence after excluding inadmissible DNA evidence | State claims total evidence supports verdicts. | If DNA evidence excluded, without it guilty verdicts fail. | Evidence, viewed with admissible and inadmissible, supports verdicts; retrial not discharge. |
| Application of Williams to DNA testimony with non-testifying lab reports | Williams supports excluding such testimony. | Williams controls, leads to error. | Williams is distinguishable; no error found here. |
| Treatment of lab printouts and hearsay under Louisiana law | Printouts are admissible as records; non-hearsay under 803(6/8). | Printouts cannot be statements of declarants. | Computer printouts and related technician assertions admissible under hearsay exemptions. |
Key Cases Cited
- State v. Hearold, 603 So.2d 731 (La. 1992) (complete evidence review includes admissible and inadmissible evidence)
- Lockhart v. Nelson, 488 U.S. 33 (U.S. 1988) (new trial if not supported by evidence after errors)
- Williams v. Illinois, 567 U.S. 50 (U.S. 2012) (DNA report by non-testifying lab; confrontation analysis depends on circumstances)
- State v. Long, 408 So.2d 1221 (La. 1982) (direct scientific evidence linking defendant to crimes)
- Armstead, 432 So.2d 837 (La. 1983) (distinguishing computer-stored statements from hearsay)