State v. Jones, 2015 UT 19

Background

On Feb 24, 2004 officers found Tara Brennan dead in the back seat of her Honda; cause of death was strangulation with evidence of a struggle and cocaine in her system. A belt ligature and fingernail scrapings were collected. Brennan’s wallet was missing.
Conventional autosomal STR testing on a cigarette butt from inside the car matched Michael Jones; police interviewed Jones in 2004 and again in 2006; Jones admitted being with Brennan that night, buying and smoking crack with her, and smoking cigarettes in her car.
In 2006 the State obtained Y‑STR testing (male‑only Y‑chromosome analysis) of the belt and fingernail samples; experts testified the profile could not exclude Jones and excluded about 99.6% of the male population (roughly a 1-in-2,681 frequency based on available databases).
At trial Jones was convicted of murder, aggravated robbery, and unlawful distribution. He appealed, raising multiple evidentiary and constitutional claims and alleging cumulative error; the Utah Supreme Court affirmed.
Key legal disputes on appeal: admissibility and probative value of Y‑STR DNA as identification evidence (Rule 702/403); admission/exclusion of Jones’s second police interview excerpts (Rule 106/hearsay); admission of an officer’s anecdotal statistical testimony about drug‑driven crime; alleged prosecutorial misconduct during closing; and sufficiency of the evidence for murder and aggravated robbery.

Issues

Issue	Plaintiff's Argument (State / Prosecution)	Defendant's Argument (Jones)	Held
Admissibility of Y‑STR DNA under Rule 702	Y‑STR methodology is generally accepted; results reliably assist the trier of fact and were explained to jury	Y‑STR is unreliable for identification (even if method is valid) and is unduly prejudicial under Rule 403	Court affirmed admission: Y‑STR methodology is generally accepted; limitations go to weight, not admissibility, and explanation to jury avoided unfair prejudice
Rule 106 / admissibility of full second police interview	State relied on detective’s testimony and excerpts; full recording not necessary	Trial court erred in excluding the complete 2006 interview after State read excerpts; exclusion misled jury; ineffective assistance for counsel’s cross‑examination	Court affirmed exclusion: detective’s testimony and cross‑examination sufficiently placed excerpts in context; counsel’s conduct not objectively deficient
Officer testimony that "90% of crime is drug‑driven"	Offered as expert opinion based on officer’s narcotics experience as a permissible, quantifiable professional observation	Testimony was prejudicial anecdotal statistical evidence and should have been excluded; plain error or ineffective assistance	Not preserved; no plain error—testimony was quantifiable opinion, foundation adequate, and not unfairly prejudicial
Prosecutorial comments in closing (e.g., "red herrings", inferences about strength, clothes, gang/carjacking)	Prosecution argued permissible inferences and deductions from evidence	Comments were misconduct: improper appeals to facts not in evidence, personal opinion, and misstatements	No plain error: most remarks were permissible inferences or harmless; misstatements were not obviously prejudicial and did not undermine fairness

Key Cases Cited

State v. Maestas, 299 P.3d 892 (Utah 2012) (upheld admissibility of Y‑STR DNA and discussed its probative limitations)
State v. Butterfield, 27 P.3d 1133 (Utah 2001) (recognized reliability of traditional PCR STR DNA for identification)
State v. Cruz‑Meza, 76 P.3d 1165 (Utah 2003) (preservation and standard of review for evidentiary rulings)
State v. Holgate, 10 P.3d 346 (Utah 2000) (plain‑error standard and preservation rules)
Archuleta v. Galetka, 267 P.3d 232 (Utah 2011) (standards for ineffective assistance review)
State v. Dunn, 850 P.2d 1201 (Utah 1993) (cumulative‑error doctrine and prosecutor argument scope)