State v. Ruff

Summary

The Supreme Court of Missouri held that Huntley Ruff's motion for post-conviction DNA testing adequately alleged that identity was at issue and satisfied the pleading requirements of Missouri Revised Statutes section 547.035. The court reversed the denial of the motion without a hearing and remanded for appropriate DNA testing and relief.

Holdings

1. The statutory requirement that identity be at issue is broader than a claim of mistaken identity. Identity is at issue when a defendant claims he did not commit the charged acts, even if he does not specifically assert that another person committed the crime.
2. Ruff's motion adequately alleged the statutory prerequisites for DNA testing, and any potential pleading deficiencies were negated by the State's admission that vaginal swabs had been collected and likely contained semen from the rapist.
3. The motion court clearly erred by overruling Ruff's motion without a hearing; the case must be reversed and remanded for appropriate DNA testing and relief under section 547.035.7.

Questions Presented

1. Whether Ruff's motion adequately alleged that identity was an issue in the trial under section 547.035.2(4), even though his trial counsel stated that the case was not one of mistaken identity.
2. Whether Ruff's motion satisfied the pleading requirements for DNA testing under section 547.035 when it identified potentially testable evidence and alleged a reasonable probability of a different result.
3. Whether the motion court clearly erred by overruling the DNA-testing motion without a hearing.

Disposition

reversed_and_remanded