Rodriguez v. State

After a seven-day jury trial, Kevin Rodriguez was found guilty of multiple criminal counts. Rodriquez appealed, arguing that the district court erred (1) in overruling his objection to the admission of twelve text messages because the State failed to authenticate the messages and the messages constituted inadmissible hearsay, and (2) in overruling his objection to the admission of DNA nonexclusion evidence because the evidence was irrelevant without supporting statistical data. The Supreme Court affirmed, holding that the district court (1) abused its discretion in admitting ten of the twelve text messages because the State failed to present sufficient evidence corroborating Appellant's identity as the person who sent the ten messages, but the error was harmless; and (2) did not abuse its discretion by admitting the relevant DNA nonexclusion evidence because, so long as it is relevant, DNA nonexclusion evidence is admissible because any danger of unfair prejudice or of misleading the jury is substantially outweighed by the defendant's ability to cross-examine or offer expert witness evidence as to probative value.