State of Maine v. Jeffrey A. Cookson

Summary

The Maine Supreme Judicial Court affirmed the denial of Jeffrey A. Cookson’s motion for a new trial under Maine’s post-conviction DNA analysis statute. The court held that Cookson failed to prove by clear and convincing evidence that only the perpetrator could have been the source of a hair found in a victim’s hand. The court concluded that the hair could have originated from other plausible sources.

Holdings

1. Under 15 M.R.S. § 2138(10)(A)-(B), a defendant must establish by clear and convincing evidence that only the perpetrator could have been the source of the DNA evidence, in addition to satisfying the applicable actual-innocence or probable-different-verdict requirement.
2. Cookson failed to prove by clear and convincing evidence that the hair found in the victim's hand could only have come from the perpetrator.

Questions Presented

1. Whether Cookson satisfied the statutory prerequisite that only the perpetrator could have been the source of the hair recovered from the victim's hand.
2. Whether the Superior Court clearly erred in denying Cookson's motion for a new trial based on newly discovered DNA evidence under 15 M.R.S. § 2138.

Disposition

affirmed