State v. Medicine Eagle
Annotate this CaseM.E.H. alleged she was kidnapped and raped by Defendant in 2000. The charges against Defendant were dismissed when DNA testing failed to implicate him. In 2008, the case was reopened, and the evidence obtained in 2000 was retested using a new method of DNA testing, which revealed the presence of Defendant's DNA. Defendant was again indicted, and a part II information was filed charging Defendant as a habitual offender. The jury found Defendant guilty of rape in the second and third degree and related charges. In a separate trial, the jury found Defendant was a habitual offender. The Supreme Court reversed, holding that the trial court (1) did not abuse its discretion in admitting evidence of an incident involving another alleged victim as other acts evidence; (2) did not violate Defendant's right to confrontation by admitting testimony regarding the results of the DNA testing performed in 2008 and 2011, even though some steps of the testing were performed by nontestifying analysts; but (3) because the State's filing of an amended part II information effectively dismissed the original part II information, the State's dismissal of the amended part II information left the trial court without jurisdiction over the habitual offender proceedings. Remanded for resentencing.
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