Case Analysis: Andrews v. State of Florida

Introduction

The case Andrews v. State of Florida 533 So.2d 841 (1988) was appealed to determine the admissibility of DNA evidence in court. In this case, the victim to the crime narrated that she was awaked late in the night by someone who jumped on her and threatened to kill in case she could look at his face. Upon investigations, Andrews was identified as the primary suspect and was arrested while more investigation was done. The intruder had a sharp object which he used as a tool of threatening the victim before proceeding to rape her despite the struggle by the victim to free herself which bore no success. The suspect made away with $40 in a purse leaving the victim injured after cuts in her neck, body, and legs. After the incident, the victim reported to the police where a swab sample of semen was obtained from her vagina. The analysis of the swab sample helped to establish a section of the population where the suspect was highly likely to come from. Upon further investigation of the scene of the crime, it was confirmed that the fingerprints found belonged to the suspect in custody. A new search in the victim's house found out that the fingerprints that had been left out by the suspect matched to those of his right and middle finger. The prosecution admitted the evidence from the DNA, and the court admitted it was leading to the sentencing of the suspect on charges sexual and aggravated battery together with armed robbery. The convict appealed the sentencing against the State of Florida questioning the methods used by the analyzing company along with the admissibility of evidence from DNA samples. The appellant further questioned why the same incident could lead to a conviction of aggravated and sexual battery.

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The legal issue that arose from the case was whether evidence from DNA samples is admissible by the court. In the ruling, the appellate court upheld the decision of the trial court that evidence from DNA sample was admissible. In the ruling, the court cited some incidences where DNA evidence had been used to exonerate suspects of the crime. The court noted that the evidence submitted by the appellee conformed with all the scientific procedures required to be followed during investigations (Magalhaes et al., 2015). In this evidence, the prosecution had established a statistical formula according to the provisions of Hardy-Weinburg equilibrium (Kayser, 2015). According to the formula, a population has DNA bands that are calculated with the established formula. In this case, the statistical formula had been established to determine a section in which the DNA sampled belonged. It the testimony, it was admitted that even if the sample base was enlarged, it was hard to change the statistical probability of numbers. The finding conformed with the research by The American Association of Blood Banks which established that an average of 2-500 samples was enough to provide statistical results (Lynch, 2013). The court through the previous case of United States v. Ferri, 778 F.2d 985 (3d Cir.1985) affirmed that the expert testimony from Life Codes Corp was reliable to be admitted in court.

The case had an impact on the admissibility of forensic evidence in criminal prosecution. In most cases, the issue of concern in forensic evidence is its reliability when presented in court. The evidence should be reliable such that it should follow all the scientific procedures in its determination and that expert testimony should be from a person or an institution that is professional and qualified to conduct the examination (Buckleton, Bright & Taylor, 2016). The case impacted the use of DN samples in prosecution has it revisited past cases of the same magnitude and either upheld the rulings of previous judges or provided a new direction for future cases involving DNA samples (Buckleton, Bright & Taylor, 2016). The main concern of forensic evidence is the reliability of the evidence. The issue of reliability should be able to meet the threshold of being done by a qualified person, follow the technique of novelty and also be supported by expert testimony from an independent party. All future cases involving similar issues must be subjected to the test of reliability before the court can decide if they are admissible.

The case State v. Schwartz 447 N.W.2d 422 (1989) has built upon the selected case where statistical evidence should be established before admitting DNA sample evidence. In the case, the judges rejected the tests results as inadmissible by challenging the reliability of the test results. The expert should introduce statistical evidence to prove that an insignificant number of the population has the characteristics of the suspect (Buckleton, Bright & Taylor, 2016). By establishing the statistical evidence, it helps to prove beyond doubt that there is no other person outside apart from the suspect who could be responsible for the crime. The case of Andrews was admissible because there was statistical evidence of 0.0000012% which allowed the appellate court to uphold the conviction of the trial court (Kayser, 2015). All future cases involving forensic evidence have therefore established the importance of statistical evidence in determining the reliability of DNA samples when presented to the courts as evidence.

References

Buckleton, J. S., Bright, J. A., & Taylor, D. (Eds.). (2016). Forensic DNA Evidence Interpretation. CRC press.

Kayser, M. (2015). Forensic DNA Phenotyping: Predicting Human Appearance from Crime Scene Material for Investigative Purposes. Forensic Science International: Genetics, 18, 33-48.

Lynch, M. (2013). Science, Truth, and Forensic Cultures: The Exceptional Legal Status of DNA Evidence. Studies in History and Philosophy of Science Part C: Studies in History and Philosophy of Biological and Biomedical Sciences, 44(1), 60-70.

Magalhaes, T., Dinis-Oliveira, R. J., Silva, B., Corte-Real, F., & Nuno Vieira, D. (2015). Biological Evidence Management for DNA Analysis in Cases of Sexual Assault. The Scientific World Journal, 2015.