Phillips v. State
Annotate this CaseDefendant was charged with two counts of first-degree murder. The police obtained DNA samples from the crime scene. The DNA analysis was conducted in accordance with the FBI’s Quality Assurance Standards. Prior to trial, Defendant filed a motion in limine to exclude the State’s DNA evidence and related expert testimony, arguing that the evidence was not admissible because the analysis was not performed in accordance with standards established by one of the two entities named in Md. Code Ann. Cts. & Jud. Proc. (CJP) 10-915 and because the methods of analysis that were used are not generally accepted as reliable under Frye-Reed. The trial court and Court of Special Appeals held (1) the DNA evidence did not qualify for automatic admissibility under section 10-915; but (2) the evidence was nonetheless admissible under Frye-Reed. The Court of Appeals affirmed, holding (1) the DNA evidence was automatically admissible under CJP 10-915; and (2) therefore, the trial court should not have conducted a Frye-Reed hearing to determine its admissibility, but the error was harmless because the trial court ultimately reached the correct conclusion that the DNA evidence was admissible.
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