John Britt v. State of Arkansas

2025 Ark. App. 412
CourtCourt of Appeals of Arkansas
DecidedSeptember 10, 2025
StatusPublished

This text of 2025 Ark. App. 412 (John Britt v. State of Arkansas) is published on Counsel Stack Legal Research, covering Court of Appeals of Arkansas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
John Britt v. State of Arkansas, 2025 Ark. App. 412 (Ark. Ct. App. 2025).

Opinion

Cite as 2025 Ark. App. 412 ARKANSAS COURT OF APPEALS DIVISION III No. CR-24-383

JOHN BRITT Opinion Delivered September 10, 2025 APPELLANT APPEAL FROM THE BENTON COUNTY CIRCUIT COURT V. [NO. 04CR-16-2178]

STATE OF ARKANSAS HONORABLE BRAD KARREN, JUDGE APPELLEE

AFFIRMED

BART F. VIRDEN, Judge

Appellant John Britt appeals from the Benton County Circuit Court’s order denying

his petition for postconviction relief pursuant to Ark. R. Crim. P. 37.1. Britt argues on appeal

that his trial counsel were ineffective in that they (1) failed to properly challenge the

admissibility of the State’s DNA evidence under Daubert v. Merrell Dow Pharmaceuticals, Inc.,

509 U.S. 579 (1993); (2) failed to consult with an expert before filing a motion in connection

with the Daubert hearing; (3) failed to ensure that the defense expert was adequately prepared

prior to the Daubert hearing; (4) presented damaging DNA-related testimony from his own

expert; (5) failed to properly cross-examine the State’s DNA experts at trial; (6) failed to

present expert DNA testimony on his behalf at trial; and (7) failed to adequately or properly

attack the statistical evidence presented by the State’s expert at trial. We affirm the trial

court’s denial of relief. I. Procedural Background

In January 2017, Britt was charged with raping his then thirteen-year-old daughter. A

rape kit was performed, and DNA material from the minor child’s (MC’s) body and her

clothing were sent to the Arkansas State Crime Laboratory (“crime lab”) for testing. Because

insufficient DNA material was present on the samples provided, the more common

autosomal DNA testing could not be done; instead, Y-STR testing was performed. “Y-STR”

means short tandem repeat of the Y chromosome. Britt v. State, 2019 Ark. App. 145, at 1

n.1, 573 S.W.3d 567, 568 n.1 (“Britt I”). Y-STR testing amplifies the male Y chromosome

and excludes those men who do not share the same paternal lineage. Id. at 2, 573 S.W.3d at

569. The profiles created from the samples of DNA material from MC’s body and clothing

using the Y-STR testing were consistent with Britt’s profile created through autosomal testing

of a known sample of Britt’s DNA.

Britt filed a motion requesting a Daubert hearing to challenge the admissibility of

expert testimony with respect to Y-STR testing of the DNA evidence. Under Daubert, the

trial court must make a preliminary assessment of whether the reasoning or methodology

underlying expert testimony is valid and whether the reasoning and methodology used by

the expert has been properly applied to the facts in the case. The trial court granted Britt’s

request for a hearing. At the hearing, Britt presented testimony from Mary Robinette, a

retired chemist formerly employed by the crime lab. Robinette testified generally that Y-STR

is a valid science and said that Y-STR testing plays “a great role” in forensics. She also

2 explained the limitations of Y-STR testing and expressed concerns with the testing in this

case. Robinette noted possible cross-contamination due to the rushed process and confusion

over the source of the statistics. The trial court ultimately denied Britt’s motion to exclude

the DNA evidence after finding that Y-STR testing is reliable and that expert testimony on

the subject could be helpful to the jury.

At trial, the State presented testimony by Julie Butler, the DNA analyst who tested

the samples in this case, and Ada LeDoux, a serologist. The State also presented testimony

by the victim. MC testified that Britt forced her to perform oral sex on him and that it later

progressed to vaginal intercourse. Britt did not call Robinette or any other DNA expert at

trial. Britt and his wife, Hannah, testified. A jury found Britt guilty of rape, and he was

sentenced to forty years’ imprisonment. He filed an appeal, challenging the admissibility of

expert testimony regarding the Y-STR testing of the DNA evidence. We affirmed his

conviction in Britt I.

Britt subsequently filed a petition for postconviction relief pursuant to Rule 37. He

was granted permission to amend his petition. He sought an extension to hire a DNA expert,

but the trial court denied his request. Before filing his amended petition, Britt moved for a

continuance so that his recently hired DNA expert could review the evidence. The trial court

denied this request as well. The trial court then denied Britt’s Rule 37 petition without an

evidentiary hearing. Britt appealed, and we reversed and remanded because the trial court

erred in finding that time constraints prevented it from granting Britt’s motion to file an

3 enlarged petition and further erred by applying the wrong standard for granting or denying

an evidentiary hearing. Britt v. State, 2022 Ark. App. 58, 639 S.W.3d 919 (“Britt II”).

On remand, Britt filed his amended Rule 37 petition, raising the arguments he now

raises on appeal, and the trial court held an evidentiary hearing at which Britt called Kevin

Lammers and Sam Hall, the Benton County public defenders who had been appointed to

represent him. Britt also called Mehul Anjaria to testify about the DNA evidence. The State

presented two witnesses from the crime lab: Mandi Wertenberger, a forensic serologist and

physical-evidence supervisor, and Jennifer Beaty, supervisor of the forensic DNA section.

Relevant to Britt’s arguments on appeal from the denial of his Rule 37 petition is the

following testimony from the evidentiary hearing:

Lammers testified that he did not recall having any direct participation in the

preparation for the Daubert hearing. Lammers testified that he thought that filing the motion

was sufficient to preserve the issue for appeal and that it was “not something that I

anticipated as being a waiver.” He stated that the court of appeals appeared to have

considered the issue even though the Daubert factors were not argued, so the matter was

preserved to some extent. Lammers admitted that he and Hall could have done a better job

with a few things—for example, the selection of an expert for the Daubert hearing. He testified

that he did not think Robinette’s testimony was helpful to Britt but said they moved on after

the Daubert hearing to focus on cross-examining the State’s expert on the reliability of the Y-

STR testing of evidence and the possibility of cross-contamination. Lammers testified that

they sought to show the limitations of Y-STR testing and how it was useful for excluding

4 suspects but not for identifying them. He said that they focused on trying to keep out the Y-

STR DNA evidence through Arkansas Rule of Evidence 403 instead of Daubert because of

its confusing nature and because a jury was likely to simply seize on its being “DNA evidence”

without understanding the Y-STR testing. Lammers pointed out that, aside from the

admission of the Y-STR DNA evidence, there was still the presence of the antigen p30 and

the victim’s testimony.

Hall testified that he did not think DNA was the State’s strongest evidence against

Britt; rather, it was Britt’s interview with the police, which was hard to overcome because

Britt did not specifically deny having raped MC. Hall testified that he knew “from the get-

go” that Daubert was “a losing issue” and that he should focus on Rule 403 and the difference

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Related

Strickland v. Washington
466 U.S. 668 (Supreme Court, 1984)
Daubert v. Merrell Dow Pharmaceuticals, Inc.
509 U.S. 579 (Supreme Court, 1993)
Wheeler v. State
2015 Ark. 233 (Supreme Court of Arkansas, 2015)
Northern v. State
2015 Ark. App. 426 (Court of Appeals of Arkansas, 2015)
Burnside v. State
2015 Ark. App. 550 (Court of Appeals of Arkansas, 2015)
Sims v. State
2015 Ark. 363 (Supreme Court of Arkansas, 2015)
Perez v. State
2016 Ark. App. 291 (Court of Appeals of Arkansas, 2016)
Sylvester v. State
2017 Ark. 309 (Supreme Court of Arkansas, 2017)
Britt v. State
2019 Ark. App. 145 (Court of Appeals of Arkansas, 2019)
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Willie Antone Matlock v. State of Arkansas
2020 Ark. App. 399 (Court of Appeals of Arkansas, 2020)
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