United States v. Trevor Seward
135 F.4th 161
| 4th Cir. | 2025Background
- Trevor Seward was convicted by a jury of murdering rural mail carrier Irene Pressley, along with firearm, robbery, and drug offenses.
- Evidence included: Seward's fingerprints and palm prints in Pressley’s car and on packages, video footage of Seward with an assault rifle after Pressley did not deliver a package, witness testimony, and forensic findings.
- At trial, the government presented expert testimony from a firearms toolmark examiner and a DNA expert who had not personally handled the physical evidence.
- Seward attempted to introduce evidence that another witness failed a polygraph, suggesting alternative culpability.
- On appeal, Seward raised evidentiary objections under Rule 702, challenged exclusion of polygraph evidence, and claimed a Confrontation Clause violation related to the DNA testimony based on the Supreme Court’s recent decision in Smith v. Arizona.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Qualification of Toolmark Examiner | Examiner lacked scientific reliability and sufficient qualifications. | Examiner was qualified with extensive experience and ATF review. | Admission was within district court’s discretion; no abuse found. |
| Exclusion of Polygraph Evidence | Exclusion undermined defense suggesting another person’s guilt. | Polygraph results are inadmissible under per se rule; jury could be misled. | No abuse of discretion in exclusion; jury was allowed to hear about deceptive conduct instead. |
| Confrontation Clause Violation (DNA Testimony) | DNA expert’s testimony relied on non-testifying analyst’s work, violating the right to confront. | Expert gave an independent opinion, consistent with prior circuit precedent. | Smith v. Arizona abrogates earlier precedent, so testimony likely violated Confrontation Clause, but error was harmless beyond a reasonable doubt. |
Key Cases Cited
- Crawford v. Washington, 541 U.S. 36 (Seminal decision on Confrontation Clause and testimonial statements.)
- Melendez-Diaz v. Massachusetts, 557 U.S. 305 (Forensic lab reports are testimonial for Confrontation Clause purposes.)
- Bullcoming v. New Mexico, 564 U.S. 647 (Substitute expert’s testimony cannot admit non-testifying analyst’s testimonial material.)
- Delaware v. Van Arsdall, 475 U.S. 673 (Harmless error analysis applies to Confrontation Clause violations.)
- Chapman v. California, 386 U.S. 18 (Sets the standard for harmless constitutional error.)