State v. Wright
253 P.3d 838
Mont.2011Background
- Wright was convicted of sexual intercourse without consent after a three-day jury trial in Gallatin County.
- Sierra, the victim, described a rape occurring after a date on January 11, 2008, with Wright allegedly forcing sex.
- DNA evidence involved a penile swab from Wright with a mixed DNA profile including Sierra's DNA.
- The State's DNA expert testified the minor contributor could not be excluded and matched Sierra at 16 loci, with Wright as the major contributor.
- Sierra's DNA statistics were presented as population frequencies; the defense cross-examined and the court allowed closing arguments on interpretation.
- Wright was sentenced to 50 years in prison; he later acknowledged the rape during sentencing and apologized.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the DNA evidence presentation violated due process | Wright argues the State misstated DNA evidence, making Sierra appear conclusively the contributor | State claims any mischaracterization was not false, and evidence was not material | No due process violation; misstatements were not proven false or material enough |
| Whether the ineffective-assistance claim is properly before the Court on direct appeal | Wright contends trial counsel failed to adequately challenge the DNA evidence | State argues the record lacks explanations for counsel's strategy/actions | Claim dismissed without prejudice; may be raised in a postconviction petition |
| Whether the DNA testimony was sufficiently probative without unduly prejudicing the defendant | Wright asserts the testimony overstated certainty of Sierra’s involvement | State asserts context, cross-examination, and non-DNA evidence supported the State’s theory | Court declines to reverse; evidence viewed in light of full record did not violate due process |
| Whether Napue/Hayes standards apply to assess the alleged false testimony | Wright relies on Napue/Hayes to show prosecutorial knowingly false or uncorrected testimony | State argues prosecutor’s error was not knowing or material | No basis for reversal under Napue/Hayes; no material false testimony established |
Key Cases Cited
- Napue v. Illinois, 360 U.S. 264 (1959) (due process when false evidence is knowingly presented or not corrected)
- Hayes v. Brown, 399 F.3d 972 (9th Cir. 2005) (per se reversal not required; must show material false testimony)
- Commonwealth v. Mattei, 455 Mass. 840 (Mass. 2010) (explains DNA probabilistic interpretation and statistics)
- Young v. State, 388 Md. 99 (Md. 2005) (discusses limits of random match probability versus source attribution)