The Louisiana Supreme Court has overturned the conviction of Jimmie “Chris” Duncan, who spent 28 years on death row for a crime he did not commit. The court’s unanimous decision on Monday upheld a lower court’s ruling that Duncan’s 1998 conviction was based on flawed forensic practices, specifically discredited bite mark evidence.
Justice Cade R. Cole, writing for the seven-member court, stated that new evidence presented by Duncan’s legal team “undermined the core factual premises on which the state depended.” This decision comes after a thorough examination of the forensic evidence used to convict Duncan, which has since been widely discredited.
The Role of Discredited Forensic Evidence
The conviction of Jimmie Duncan was largely based on the testimony of forensic dentist Michael West and pathologist Steven Hayne. Their analysis claimed to match marks on the victim’s body to Duncan’s teeth. However, experts have since deemed such evidence to be junk science. The partnership between West and Hayne has been scrutinized by civil rights attorneys, forensic experts, and the courts due to concerns about the validity of their techniques.
In the 28 years since Duncan’s trial, nine other prisoners have been set free after being convicted in part on inaccurate evidence given by West and Hayne. Three of those men were on death row. Duncan was the last person awaiting an execution based on the pair’s work. The court’s ruling reexamined the use of supposed bite marks, which were the only physical evidence tying Duncan to the alleged crime.
The Impact of the Supreme Court’s Decision
Chief Justice John Weimer, in a concurrence, likened the use of bite mark analysis to “trial by water” tests used by witch-hunters in the 17th century. He wrote, “We now look back at those practices as asinine and absurd, since those who fell victim to those practices often did not survive, regardless of whether they were found guilty or innocent.” Weimer emphasized the irreversible and tragic consequences of carrying out the death penalty based on evidence devoid of legitimacy.
The court’s decision highlights the importance of careful consideration in death penalty cases due to the finality of the sentence and the impossibility of rectification. The ruling also underscores the need for the legal system to adapt to new scientific evidence that discredits outdated forensic practices.
The Path to Exoneration
Duncan’s prosecution began on Dec. 18, 1993, when he was babysitting Haley Oliveaux, the toddler daughter of his then-girlfriend. Duncan told law enforcement he had put the child in the bath and then went downstairs to wash dishes. When he heard a noise, he rushed upstairs to find Haley floating face down in the water. She was pronounced dead a few hours later.
Initially charged with negligent homicide, prosecutors upgraded the charge to first-degree murder after Hayne and West conducted Haley’s medical exam and claimed they discovered evidence of sexual assault and intentional drowning. Following two weeks of testimony during the trial in 1998, the jury found Duncan guilty and sentenced him to death.
While awaiting an execution date, Duncan’s new team of postconviction attorneys uncovered evidence pointing to his innocence, including an expert witness who said the child’s death was an accidental drowning. Additionally, a jailhouse informant recanted his earlier trial testimony that Duncan had confessed to the crime. Duncan’s conviction was overturned in April of last year by former Ouachita Parish Judge Alvin Sharp, and he was released on bail in December.
District Attorney Steve Tew has insisted on Duncan’s guilt and appealed Sharp’s decision to the state Supreme Court. During oral arguments in April, Tew argued that since Duncan was the only person with Haley at the time of her death, his guilt could not be debated. However, the Supreme Court’s decision affirms that the evidence used to convict Duncan was flawed and unreliable.
In addition to the Innocence Project, Duncan’s legal team includes the Mwalimu Center for Justice in New Orleans and the Bryan Cave Leighton Paisner law firm in Atlanta. The court’s decision represents a significant victory for supporters of post-conviction laws that seek to give prisoners who obtain fresh evidence of their innocence easier paths to overturning unjust sentences.
