Caldwell v. State, 260 Ga. 278

Summary

The Supreme Court of Georgia reviews a capital case on pretrial review and addresses the admissibility of forensic DNA identification evidence, including laboratory procedures, match determination, and population-statistics calculations. The court also upholds consensual searches of the defendant's apartment and truck and rejects challenges concerning discovery of recordings and an opposing expert's scientific report. The DNA evidence ruling is affirmed except that the State may not use Lifecodes' claimed identity probability based on an unestablished Hardy-Weinberg equilibrium assumption, although more conservative figures may be used.

Holdings

1. Under Georgia law, admissibility of a novel scientific procedure is determined by whether the procedure has reached a scientific stage of verifiable certainty or rests upon the laws of nature, rather than by counting heads in the scientific community.
2. A trial court evaluating forensic DNA evidence must determine not only whether the underlying scientific principles and techniques are valid and capable of producing reliable results, but also whether the laboratory substantially performed the procedures in an acceptable scientific manner.
3. Visual declaration of a DNA match may be scientifically acceptable when it is confirmed by a scientifically acceptable test for determining band shift.
4. The State could not use Lifecodes' claimed power of identity based on an assumption that the relevant population was in Hardy-Weinberg equilibrium because the State had not scientifically established that assumption; the State could use the more conservative database-based figures supported by the evidence.
5. The searches did not violate the Fourth Amendment because the apartment searches were based on the consent of the defendant's wife, the sole lessee, and the truck was searched after the defendant abandoned it.
6. The trial court did not err by denying the defendant's request for production of any and all audio and video recordings of interviews with State witnesses.
7. The State is entitled to obtain a copy of a defendant's written scientific expert report on the same reciprocal basis that the defendant may obtain the State's expert report, and the defendant's expert may be called as a witness by the State.

Questions Presented

1. Whether forensic DNA identification evidence was admissible under Georgia's standard for determining the scientific reliability of a novel procedure.
2. Whether the trial court properly considered Lifecodes' laboratory procedures and protocols, in addition to the general validity of DNA identification techniques, in determining admissibility.
3. Whether the State could present Lifecodes' claimed population-statistical power of identity based on an assumption that the relevant population was in Hardy-Weinberg equilibrium when the State had not scientifically established that assumption.
4. Whether police searches of the defendant's apartment and the later search of his abandoned truck violated the Fourth Amendment.
5. Whether the defendant was entitled to production of any and all audio and video recordings of interviews with State witnesses.
6. Whether the State was entitled to obtain a copy of the defendant's expert's written scientific report and to call that expert as a witness.

Disposition

other