Breest v. NH AG

2008 DNH 012
CourtDistrict Court, D. New Hampshire
DecidedJanuary 18, 2008
DocketCivil 06-cv-361-SM
StatusPublished

This text of 2008 DNH 012 (Breest v. NH AG) is published on Counsel Stack Legal Research, covering District Court, D. New Hampshire primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Breest v. NH AG, 2008 DNH 012 (D.N.H. 2008).

Opinion

Breest v. NH AG 06-CV-361-SM 01/18/08 UNITED STATES DISTRICT COURT

DISTRICT OF NEW HAMPSHIRE

Robert B r e e s t , Plaintiff

v. Civil No. 06-CV-361-SM Opinion No. 2008 DNH 012 Attorney General for the State of New H a m p s h i r e . Defendant

O R D E R

Plaintiff, Robert Breest, was convicted of the murder of

Susan Randall over thirty years ago in state court. He was

sentenced to life in prison and has remained incarcerated ever

since. He seeks access to genetic material removed from under

Ms. Randall's fingernails for the purpose of subjecting it to

forensic DNA testing, in the hope of developing evidence to

support a claim of actual innocence. The defendant. New

Hampshire's Attorney General, who has custody of the material,

has moved to dismiss Breest's complaint on several grounds.

Susan Randall apparently "clawed her assailant 'to the

bone'"1, and it seems generally uncontested at this point, given

the record developed in Breest's state criminal case, that modern

1 State v. B r e e s t . No. 72-S-789, New Hampshire Superior Court (Conboy, J.) (July 12, 2007). DNA testing might establish that he was not the murderer, if,

that is, he can be excluded as a contributor to the DNA found

under Ms. Randall's fingernails.

Breest first sought access to the genetic material in March

of 2000, in the context of his state criminal prosecution. He

filed a motion to "bring [the case] forward," and asked the state

court to order DNA testing. See State v. B r e e s t . No. 72-S-789,

New Hampshire Superior Court (Merrimack C o u n t y ) . The New

Hampshire Superior Court considered Breest's motion as one in

support of a potentially meritorious motion for a new criminal

trial, and ordered the requested DNA testing under applicable

state law, finding, inter a l i a , that DNA test results would have

been admissible at his criminal trial had the technology been

available, and that such test results would have been highly

probative of his guilt or innocence. Id.

Three DNA tests were eventually performed on the genetic

material by Cellmark Diagnostics, a private laboratory located in

Germantown, Maryland. Cellmark reported that the first test,

performed in March of 2001, proved inconclusive, apparently

because the questioned sample contained a mixture of the victim's

female chromosomes and the assailant's male chromosomes.

2 A second test was performed in April of 2001. That test

(YSTR testing at 4 loci) was capable of eliminating that common

source of ambiguity in the testing process — a mixture of male

and female chromosomes — by testing only for male chromosomes.

Cellmark reported that it was able to compare the known and

questioned material at 3 of the 4 loci examined, and that Breest

could not be excluded as the source of the male DNA. Breest

responded with affidavits from four experts in the field who

opined that Cellmark's conclusions were flawed and the DNA

testing procedures it employed were unreliable.

Given those criticisms, the Superior Court allowed

additional access to the genetic material for a second round of

YSTR testing in January of 2002. Cellmark again performed the

test, and again reported that Breest could not be excluded as the

source of the male DNA in the sample, noting a match between his

DNA and that in the sample at the 4 loci examined. One in ten

Caucasian males (Breest is Caucasian) could expect their DNA to

match the sample at the 4 loci examined in the test.

In May of 2004, Breest sought another DNA test, again in the

context of his state criminal case. DNA technology had improved

significantly since the 2002 testing, and a 12 loci YSTR test was

3 then available. The 12 loci test is more discriminating than the

earlier tests that examined only 4 loci. The Superior Court

denied that request, however, finding that Breest failed to

demonstrate "why the tests already conducted are not accurate or

why further testing would demonstrate his actual innocence or

would result in a different verdict after trial." State v.

Breest, 72-S-789, Doc. No. 126 (McGuire, J.).

In 2006, Breest filed another motion for DNA testing in his

state criminal case, and filed this parallel federal suit as

well. In this civil case, Breest seeks prospective injunctive

relief against New Hampshire's Attorney General, as custodian of

the genetic material, requiring her to provide an adequate sample

for more definitive DNA testing (i.e., the more discriminating 12

loci YSTR testing, or, presumably, testing under the most

advanced protocol currently available). The state court has

again denied relief in Breest's criminal case — seemingly based

upon its finding that Breest failed to meet a specific burden

under a recently enacted state statute, RSA 651-D:2, III, that

addresses post-conviction access to genetic evidence for DNA

testing.

4 By its terms, RSA 651-D:2, III, authorizes a state court to

order post-conviction DNA testing if a petitioner establishes,

inter a l i a , t h a t :

(f) The evidence sought to be tested was not previously tested under DNA technology or the technology requested was not available at the time of trial.

[or]

(g) If DNA or other forensic testing was previously done in connection with the case, the requested DNA test would provide results that are significantly more discriminating and probative on a material issue of identity, and would have a reasonable probability of contradicting prior test results.

(emphasis a d d e d ) .

The state statute does not expressly limit the number of

post-conviction tests available to a petitioner, but instead

thoughtfully ties the availability of additional testing to

anticipated advances in technology (i.e., "significantly more

discriminating and probative" tests) that might reasonably

provide exculpatory results, different from previous test

results.

It seems evident that a substantially more discriminating

DNA test would ordinarily "have a reasonable probability of

contradicting prior test results" — if "contradicting" is

5 understood to mean "exclude the suspect where a prior DNA test

could not exclude that suspect as the source of questioned DNA.2"

For example, if the prior DNA testing, as in this case, could say

no more than that 1 in 10 Caucasian males could have contributed

the questioned DNA, and the petitioner could not be excluded from

that 10%, but new testing was sufficiently discriminating to

measure the probability of contribution at 1 in 2 billion, then

it would be fair to conclude that a "reasonable probability of

contradiction" exists. But, where the prior DNA testing was

particularly discriminating, say it established that only 1 in 3

billion Caucasian men, including the petitioner, could have been

the source of the questioned DNA, a subsequent, even more

discriminating, test that could produce a result to an accuracy

2 The term "contradictory," as used in the statute is perhaps confusing, given the context. A subsequent and more discriminating DNA test might be capable of eliminating 99.9% of all Caucasian males as the contributor, while the test performed earlier may have been capable of excluding only 50% of all Caucasian males.

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