State of Washington v. Robert Rufus Williams

Summary

The Washington Court of Appeals, Division Two, held that the trial court abused its discretion in denying Robert Rufus Williams’s motion for postconviction DNA testing. The trial court failed to articulate that it was presuming favorable DNA results and did not analyze whether those presumed results, considered with the trial evidence, could demonstrate Williams’s innocence on a more probable-than-not basis. The appellate court reversed and remanded for the required legal analysis.

Holdings

1. A court evaluating the substantive requirement of RCW 10.73.170(3) must presume that the requested DNA-test results will be favorable to the convicted person, including the absence of the person's DNA and the presence of another person's DNA when that is the favorable result asserted by the motion.
2. The trial court must assess whether the hypothetical favorable DNA results, in combination with the evidence presented at trial, would raise a reasonable probability that the convicted person was not the perpetrator and would demonstrate innocence on a more-probable-than-not basis.
3. Whether the State should have tested the evidence before trial is not relevant to the substantive determination of whether postconviction DNA evidence would demonstrate innocence under RCW 10.73.170(3), absent a dispute concerning a separate procedural requirement.

Questions Presented

1. Whether the trial court abused its discretion by failing to expressly presume that the requested DNA testing would produce favorable results for Williams.
2. Whether the trial court conducted the required analysis of whether the presumed favorable DNA results, considered together with the trial evidence, would raise a reasonable probability of Williams's innocence on a more-probable-than-not basis.
3. Whether the trial court improperly considered whether the State should have tested the evidence before trial in evaluating the substantive statutory requirement.

Disposition

reversed_and_remanded