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Taylor v. State

Court of Criminal Appeals of Oklahoma
1995 Okla. Crim. App. LEXIS 10, 1995 OK CR 10, 889 P.2d 319 (1995)
ELI5:

Sections

Rule of Law:

The standard for admitting novel scientific evidence in Oklahoma is no longer the Frye 'general acceptance' test, but rather the Daubert standard, which requires the trial judge to act as a gatekeeper determining if the evidence is both relevant and scientifically reliable.


Facts:

  • On May 23, 1988, an intruder broke into S.H.'s home where she and her mother, A.H., were present.
  • The intruder robbed the victims and subjected them to rape and forcible sodomy.
  • S.H. assisted police in creating a composite sketch, leading to the identification of Michael Anthony Taylor.
  • Taylor voluntarily provided police with samples of his blood, hair, and saliva.
  • Police collected semen and blood samples from the crime scene and the victims' clothing.
  • Because conventional testing was inconclusive, samples were sent to Lifecodes Corporation for DNA Print Identification (RFLP analysis).
  • Lifecodes scientists determined that the DNA in Taylor's blood matched the DNA found in the semen on the victims' clothing.
  • Statistical analysis indicated that the likelihood of another African American possessing the same genetic pattern was one in 97 billion.

Procedural Posture:

  • Taylor was charged with Burglary, Rape, Sodomy, and Robbery in the District Court of Oklahoma County.
  • The trial court held an in camera hearing to determine DNA admissibility under the Frye standard.
  • The trial court ruled the DNA evidence admissible.
  • A jury convicted Taylor on all counts and recommended sentences of imprisonment.
  • Taylor appealed his conviction to the Court of Criminal Appeals.
  • The Court of Criminal Appeals remanded the case to the district court for an evidentiary hearing regarding DNA acceptance and procedures.
  • The District Court conducted the evidentiary hearing and found the DNA evidence was properly admitted.
  • The case returned to the Court of Criminal Appeals for final disposition of the appeal.

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Issue:

Should the court abandon the Frye 'general acceptance' test in favor of the Daubert standard for determining the admissibility of novel scientific evidence, specifically DNA profiling?


Opinions:

Majority - Chapel

Yes, the court should abandon the rigid Frye test and adopt the more flexible Daubert standard. The court reasoned that the Oklahoma Evidence Code (Section 2702) aligns closely with the Federal Rules of Evidence, which the U.S. Supreme Court interpreted in Daubert to supersede Frye. The court established that trial judges must act as gatekeepers to ensure scientific evidence is reliable and relevant. Applying this new standard, the court found that the RFLP method of DNA profiling is testable, has been peer-reviewed, has a low error rate, and is generally accepted, making it admissible. Furthermore, the statistical probability evidence explaining the significance of the DNA match was found to be more probative than prejudicial.


Concurring - Johnson

Yes, the Daubert standard is the appropriate framework for Oklahoma. Justice Johnson emphasized that the Oklahoma Evidence Code never explicitly mandated the Frye test. He agreed that Section 2702 allows for expert testimony that assists the trier of fact, granting trial courts wider latitude to admit novel scientific evidence provided it is reliable and relevant.


Concurring - Lane

Yes, the shift to Daubert is legally valid, though it presents significant practical concerns. Justice Lane expressed concern that shifting the burden of determining scientific reliability from the scientific community (Frye) to the trial judge (Daubert) places an immense strain on the judiciary. He noted that judges lack the scientific training to easily navigate complex concepts like 'linkage disequilibrium' and 'population substructure,' fearing practical difficulties in future cases involving complex science.


Concurring - Lumpkin

Yes, the conviction should be affirmed, but the adoption of Daubert is unnecessary dicta. Justice Lumpkin argued that the DNA evidence was admissible under the existing Frye standard and that the court should not have created a new rule when the issue wasn't explicitly raised by the parties. He also highlighted that unlike federal judges, state trial judges lack the resources, clerks, and time to effectively act as scientific gatekeepers, and predicted this decision would burden the state court system.



Analysis:

This is a landmark decision in Oklahoma criminal law because it explicitly aligns state evidentiary standards with the federal Daubert standard, rejecting the decades-old Frye test. By doing so, the court shifted the focus of admissibility from 'general acceptance' by scientists to a judicial determination of 'reliability' and 'relevance.' This empowers trial judges but also imposes a significant responsibility on them to understand scientific methodology. Practically, this ruling cemented the admissibility of DNA profiling and its accompanying statistical probability evidence in Oklahoma, reducing the need for repetitive pre-trial hearings on established DNA methods.

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