Summary
The Minnesota Supreme Court reversed and remanded a district court order suppressing DNA evidence in eight criminal cases. The court held that compliance with the TWGDAM guidelines was not mandated and directed the district court to determine whether the Minnesota Bureau of Criminal Apprehension complied with appropriate standards and procedures for DNA testing; it declined to address statistical-evidence issues not properly before it.
Topics
Practice areas
Questions Presented
- Whether the State established sufficient critical impact to permit pretrial appellate review of the suppression orders.
- Whether compliance with TWGDAM guidelines was required for admission of PCR-STR DNA evidence under Minnesota's Frye-Mack standard.
- Whether the defendants' challenge to the presentation of DNA statistical evidence was properly before the Supreme Court.
Holdings
- Although the record was not sufficiently developed to establish critical impact in each case, the Supreme Court exercised its inherent authority to review the cases because the DNA-suppression issue was identical to the issue in Traylor and review served judicial economy in the unique circumstances presented.
- Compliance with TWGDAM guidelines is not mandated. The suppression order was therefore erroneous, and the case was remanded for the district court to determine whether the BCA complied with the appropriate standards and procedures for DNA testing.
- The Supreme Court declined to address the statistical-evidence issue because the defendants had not cross-appealed the district court's ruling or cross-petitioned for review.
Key quotations
“Because compliance with the TWGDAM guidelines is not mandated, we reverse and remand the matter to the district court for further proceedings to determine if the BCA has complied with the appropriate standards and procedures for DNA testing.” (567)
“Critical impact is met when the suppression of the evidence significantly reduces the likelihood of a successful prosecution.” (566)
Factual background
In eight separately charged criminal cases involving murder, criminal sexual conduct, kidnapping, and assault, blood or semen samples were analyzed by the Minnesota Bureau of Criminal Apprehension using PCR-STR DNA testing. The State alleged that the DNA results connected the defendants to victims or crime scenes. The district court found the methodology generally accepted and the laboratory matches foundationally reliable, but concluded that the laboratory had not followed TWGDAM guidelines because primer sequences were not publicly known.
Procedural history
The defendants moved to suppress DNA evidence after a combined Frye-Mack hearing. The district court found the PCR-STR methodology and the laboratory matches generally accepted and foundationally reliable, but suppressed the evidence because the Minnesota Bureau of Criminal Apprehension had not complied with Technical Working Group on DNA Analysis Method guidelines, following the Minnesota Court of Appeals' decision in Traylor. The State petitioned for accelerated review, and the Supreme Court considered the cases contemporaneously with Traylor.
Remand instructions
The district court must conduct further proceedings to determine whether the BCA complied with the appropriate standards and procedures for DNA testing, rather than treating compliance with TWGDAM guidelines as mandatory.