People v. McKinney CA3

CourtCalifornia Court of Appeal
DecidedMay 1, 2025
DocketC097572
StatusUnpublished

This text of People v. McKinney CA3 (People v. McKinney CA3) is published on Counsel Stack Legal Research, covering California Court of Appeal primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
People v. McKinney CA3, (Cal. Ct. App. 2025).

Opinion

Filed 5/1/25 P. v. McKinney CA3 NOT TO BE PUBLISHED California Rules of Court, rule 8.1115(a), prohibits courts and parties from citing or relying on opinions not certified for publication or ordered published, except as specified by rule 8.1115(b). This opinion has not been certified for publication or ordered published for purposes of rule 8.1115.

IN THE COURT OF APPEAL OF THE STATE OF CALIFORNIA THIRD APPELLATE DISTRICT (San Joaquin) ----

THE PEOPLE, C097572

Plaintiff and Respondent, (Super. Ct. No. STK-CR-FE- 2019-16711) v.

NATHANIEL JERMAINE MCKINNEY,

Defendant and Appellant.

A jury convicted defendant Nathaniel Jermaine McKinney of committing various sex offenses against his daughter when she was 13 years old. He was sentenced to 15 years to life in state prison. On appeal, McKinney seeks reversal of his convictions, claiming that the prosecutor prejudicially mischaracterized the DNA evidence in closing argument and that the trial court erred by failing to sua sponte instruct the jury on certain assertedly lesser included offenses. McKinney also challenges his sentence, contending, among other things, that he was constructively denied the assistance of counsel. Finding no prosecutorial or instructional error, we affirm the convictions. We further conclude that a remand for resentencing is unwarranted on the present record.

1 BACKGROUND McKinney was charged with forcible rape of a child (Pen. Code, § 264, subd. (c)(1); count 1), lewd acts upon a child (§ 288, subd. (a); count 2), and aggravated sexual assault of a child who is under age 14 and seven or more years younger than the perpetrator (§ 269, subd. (a)(1); count 3).1 Various defense attorneys were appointed and relieved over the course of the pretrial proceedings. Ultimately, McKinney represented himself at trial. At trial, the victim testified that McKinney, her father, raped her at his apartment one night in November 2019 when she was 13 years old. The victim reported the assault to law enforcement, and she underwent a Sexual Assault Response Team (SART) examination approximately three days after the assault occurred. During the SART exam, the nurse took two sets of swabs of multiple parts of the victim’s body to collect potential physical evidence for DNA testing. The nurse additionally obtained reference buccal swabs from the inside of the victim’s cheek. She also collected for DNA testing the underwear the victim wore to the exam. After the exam, law enforcement collected a pair of black pajama pants that the victim reportedly wore the night of the assault. Law enforcement also obtained a reference buccal swab from McKinney. The underwear, pajama pants, and evidentiary swabs were tested and analyzed at a California Department of Justice laboratory. The testing revealed sperm on one of the swabs of the victim’s mons pubis as well as on the crotch of both the pajama pants and underwear. The criminalist who performed the DNA analysis was designated as an expert and testified about the results of the testing. Using a technique called differential extraction,

1 Undesignated statutory references are to the Penal Code.

2 the expert separated the mons pubis DNA sample into a “sperm fraction” and a “non- sperm fraction.” The sperm fraction of the mons pubis swab contained DNA from two contributors, one male and one female. When the expert uploaded the male DNA profile to the Combined DNA Indexing System database, it revealed McKinney as a match. The expert also used a probabilistic genotyping software program to compare the DNA from the mons pubis swab to the DNA from McKinney’s reference buccal swab. He testified that probabilistic genotyping shows whether a person can be excluded as a contributor to a given sample, and, if he or she cannot be excluded, gives a “likelihood ratio[]” for how likely it is that the person is a DNA contributor. The likelihood ratio statistics correlate to the rarity of certain DNA variations in the population. The higher the ratio, the more likely it is that the person’s DNA is in the sample. For the sperm fraction of the mons pubis swab, having determined there was DNA from one male and one female, the expert was able to assume that the female contributor was the victim herself. Given those inputs, the genotyping software program reported that it was 81 quadrillion times more likely that the male DNA belonged to McKinney than to an unknown person. In the language of the program, this was “very strong support” that McKinney was the other contributor. The DNA expert also performed differential extractions and probabilistic genotyping on the pajama pants and underwear. For the pajama pants, the expert again determined that the sperm fraction of the sample contained DNA from two contributors. This time, however, it could not be assumed that one of the contributors was the victim, so the program provided several likelihood ratios. It was 26 sextillion times more likely that the DNA mixture was from McKinney and one unknown person instead of from two unknown people. It was 1.2 septillion times more likely that the DNA mixture was from McKinney and the victim instead of from two unknown people. And it was 31 sextillion times more likely that the DNA mixture was from McKinney and the victim instead of from an unknown person and the victim.

3 Finally, the DNA expert described the results for the sperm fraction of the underwear sample. This sample likewise contained two contributors, neither of whose identity could be assumed automatically. The program returned the following likelihood ratios: that it was 330 billion times more likely that the DNA mixture was from the victim and one unknown person instead of from two unknown people; that it was 2.2 sextillion times more likely that the DNA mixture was from McKinney and one unknown person instead of from two unknown people; and that it was 730 nonillion times more likely that the DNA mixture was from the victim and McKinney instead of from two unknown people. Again, this was “very strong support” for McKinney and the victim being contributors. When the victim was assumed to be a contributor, it became 2.5 sextillion times more likely that McKinney was the other contributor rather than an unknown person. On cross-examination, McKinney asked the DNA expert whether it was hypothetically possible for DNA to be contributed by rubbing two items together. The expert answered that “it depends” and that “in a science realm, we always say yeah, anything’s possible. But is it likely and is it probable?” Then, at the end of his cross- examination, McKinney asked the expert whether the DNA was “arguable” and whether there was “a chance the DNA test could be wrong.” The expert responded, “I mean, you can make that point. You can argue it. I mean, that’s up to you I guess.” In presenting his defense, McKinney called six character witnesses. In general, they testified that McKinney was a good father who had a good relationship with all of his children. They stated that prior to this case, they had never heard of any allegations of physical or sexual abuse by McKinney against any of his children. McKinney also testified on his own behalf. He denied all guilt, claiming the sperm found on the victim and the clothing was not his. The jury found McKinney guilty on all three counts. In a bifurcated proceeding, the jury found true two aggravating circumstances for counts 1 and 2: that the victim was

4 particularly vulnerable and that McKinney took advantage of a position of trust or confidence to commit the offenses. (Cal. Rules of Court, rule 4.421(a)(3) & (11).) The jury found not true a third aggravating circumstance that the crimes involved great violence. (Cal. Rules of Court, rule 4.421(a)(1).) In March 2022, two months after the verdicts were received, the trial court appointed counsel for McKinney.

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People v. McKinney CA3, Counsel Stack Legal Research, https://law.counselstack.com/opinion/people-v-mckinney-ca3-calctapp-2025.