WATSON v. STATE
2015 OK CR 3
| Okla. Crim. App. | 2015Background
- Petitioner Stanley Watson was convicted by jury of First Degree Murder (Case No. CF-2000-428) and sentenced to life; conviction and sentence were affirmed on direct appeal.
- Oklahoma's Postconviction DNA Act (effective Nov. 1, 2013) authorizes a motion for postconviction DNA testing.
- Watson filed a first postconviction motion for DNA testing (Jan 6, 2014); the trial court denied it because he failed to provide the required affidavit; Watson’s appeal from that denial was dismissed as untimely.
- Watson then filed a second postconviction motion for DNA testing (Apr 7, 2014); the trial court denied the second motion as procedurally barred because the issues could have been raised in his first motion.
- Watson appealed the denial of the second motion; the Oklahoma Court of Criminal Appeals affirmed, applying the Uniform Post-Conviction Act’s procedural bar for successive applications.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the Postconviction DNA Act allows successive motions for DNA testing after a first motion has been finally adjudicated | Watson contends he may file another DNA testing motion despite prior denial | State argues successive motions are barred by the procedural standards of the Uniform Post-Conviction Act | Court held Section 1086 procedural bar applies to second/subsequent DNA motions; successive motions are barred absent sufficient reason |
| Whether Watson showed a sufficient reason or excuse (including appeal-out-of-time) to overcome the procedural bar | Watson did not offer a sufficient reason for failing to raise/testing in his first motion or for missing appeal deadlines | State asserts Watson failed to establish entitlement to relief or excuse for not appealing timely | Court held Watson failed to show sufficient reason or that he was denied an appeal through no fault of his own; denial affirmed |
Key Cases Cited
- State ex rel. Smith v. Neuwirth, 337 P.3d 763 (2014 OK CR 16) (clarifies appeals under Postconviction DNA Act proceed like Uniform Post-Conviction Act appeals)
- Blades v. State, 107 P.3d 607 (2005 OK CR 1) (discusses procedural-default and appeal-timing principles in post-conviction context)
- Smith v. State, 611 P.2d 276 (1980 OK CR 43) (addresses standards for showing denial of appeal through no fault of applicant)