District Attorney’s Office v. Osborne

Brief Fact Summary.

The Due Process Clause protects against post-conviction DNA testing.

Synopsis of Rule of Law.

Osborne appealed to federal courts after he was denied the admission of DNA evidence following his 1993 kidnapping and sexual assault conviction.

Facts.

William Osborne (Osborne) was convicted of kidnapping and sexual assault in 1993. Osborne admitted guilt to the crime and was subsequently released on parole. After being charged for another crime, Osborne requested DNA testing for the 1993 crime. Osborne confessed that he asked his lawyer to request the DNA testing, but his lawyer did not do so due to the fear that the DNA results would confirm Osborne’s conviction. Osborne claimed that he admitted to guilt because he wanted a quicker release. The appellate court denied Osborne’s request because he failed to ask for the DNA testing at the 1993 trial. The Federal District Court overturned the appellate court’s decision and allowed DNA testing. The Circuit Court of Appeals affirmed and the Supreme Court of the United States granted certiorari.

Issue.

Whether the Due Process Clause protects against post-conviction DNA testing?

Held.

Yes. Reversed and remanded.

Dissent.

(Souter, J.) The state of Alaska has failed to follow its procedural processes to ensure Osborne’s due process rights despite the state’s process being sufficient.

(Stevens, J). The DNA testing would have been new evidence because the DNA testing requested by Osborne was not available at the 1993 trial. The Supreme Court’s failure to admit DNA testing violates Osborne’s due process rights.

Concurrence.

(Alito, J.) Osborne’s request should also be rejected because he must seek all state remedies through a claim of habeas corpus and he should have sought DNA testing at his 1993 trial.

Discussion.

The state of Alaska allows DNA testing for newly discovered evidence that could establish innocence on the part of the defendant. Alaska’s statutes regarding post-conviction DNA testing are similar to other states and therefore do not violate constitutionally protected due process rights. Similarly, Osborne’s right to proclaim his innocence should be brought as a habeas corpus claim.