WATSON v. STATE
2015 OK CR 3
| Okla. Crim. App. | 2015Background
- Petitioner Stanley Watson was convicted of first-degree murder, sentenced to life, and his conviction was previously affirmed on direct appeal.
- Oklahoma's Postconviction DNA Act (effective Nov. 1, 2013) allows a person to file a motion for postconviction DNA testing under 22 O.S.Supp.2013, §§ 1373–1373.7.
- Watson filed a first DNA testing motion on Jan. 6, 2014; the district court denied it on March 4, 2014 because he failed to provide the required affidavit; his appeal of that denial was dismissed as untimely.
- Watson filed a second DNA testing motion on April 7, 2014; the district court denied it on June 17, 2014 as successive and procedurally barred because the issue could have been raised in the first motion.
- Watson appealed the denial of the second motion to the Oklahoma Court of Criminal Appeals, which considered whether procedural bars from the Uniform Post-Conviction Act apply to successive DNA motions.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the Postconviction DNA Act permits successive motions for DNA testing after a first motion is finally decided | Watson contended he could file the second motion for DNA testing under the Act despite the prior denial | State argued the Uniform Post-Conviction Act's procedural bar (22 O.S. § 1086) applies to successive DNA motions | Court held § 1086’s procedural bar applies; successive motions are barred unless sufficient reason for not raising earlier is shown |
| Whether the phrase "notwithstanding any other provision of law concerning post-conviction relief" in § 1373.2(A) overrides the procedural bar of § 1086 | Watson argued that language allows DNA motions regardless of other post-conviction procedural limits | State argued that language makes the Act retroactive but does not eliminate procedural bars for successive motions | Court held the language makes the Act retroactive to final cases but does not repeal § 1086’s bar on successive motions |
| Whether Watson provided a sufficient reason for failing to raise DNA testing in his first motion | Watson did not present a sufficient explanation or seek relief to file an appeal out of time from the first denial | State noted Watson failed to seek an out-of-time appeal and did not meet burden to show denial of appeal through no fault of his own | Court held Watson failed to show sufficient reason; his second motion was barred |
| Whether a procedural bar fully precludes access to DNA testing | Watson implied successive-motion bar would preclude testing | State pointed out § 1373.6(A) allows testing when both parties agree, providing another route to testing | Court noted the bar does not completely preclude testing because testing can still occur by agreement of the parties |
Key Cases Cited
- Blades v. State, 107 P.3d 607 (Okla. Crim. App. 2005) (procedural default and timeliness principles in post-conviction appeals)
- State ex rel. Smith v. Neuwirth, 337 P.3d 763 (Okla. Crim. App. 2014) (appeal procedure under the Postconviction DNA Act follows the Uniform Post-Conviction Act)
- Smith v. State, 611 P.2d 276 (Okla. Crim. App. 1980) (standards for when appellate relief may be allowed out of time)