James v. State

Summary

The Alaska Supreme Court reviewed the denial of Daryle James's motion for a new trial based on the recantation of the prosecution's key eyewitness. The court held that the superior court erred by evaluating only the credibility of the recantation and failing to determine whether the recantation, considered with all other evidence, would probably result in an acquittal at a new trial. The court remanded for that determination.

Holdings

1. No. Under the Alaska newly discovered evidence test, assessing the credibility of a recantation is relevant but insufficient; the court must also evaluate the probable effect of the recantation at a new trial.
2. The superior court must determine whether Danielle's recantation, considered realistically in light of the totality of the evidence to be presented at a retrial, would probably produce an acquittal. If so, it must order a new trial; otherwise, the conviction stands.

Questions Presented

1. Whether a court deciding a motion for a new trial based on a witness's recantation may limit its analysis to the credibility of the recantation.
2. Whether the superior court was required to determine whether the recantation, considered with the original testimony and all other evidence available at a new trial, would probably produce an acquittal.

Disposition

reversed_and_remanded