Oregon v. Jackson
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The state charged defendant Homer Lee Jackson, III with the murder of four victims, who were killed over the span of 10 years. DNA consistent with defendant’s was found at the scene of each crime. Before trial, the state moved to cross-admit the crime scene evidence, arguing that the evidence from all four crime scenes, including the DNA evidence, was relevant to each of the four charged crimes. In support of that argument, the state relied on the doctrine of chances. The trial court denied the state’s motion to cross-admit the crime scene evidence.
The state petitioned the Oregon Supreme Court for direct interlocutory review of the trial court’s order, contending that the trial court erred in excluding the evidence from the other three crime scenes from defendant’s trial for one of the murders. The state initially argued: (1) the doctrine of chances supplied a theory of relevance for the crime scene evidence concerning the presence of defendant’s DNA near the bodies of three other murdered women; and (2) that the doctrine did not depend on prohibited inferences about defendant’s bad character and resultant propensity to commit criminal acts. In accordance with the Oregon Evidence Code, the Supreme Court initially held that the doctrine of chances, standing alone, was insufficient to make the other crime scene evidence relevant to any charged crime. In supplemental briefing, the state alternatively argued that, even if the doctrine of chances did not by itself supply the basis for the relevance of the DNA crime scene evidence, that evidence nonetheless was relevant to facts in its case by articulating a chain of inferences, ending with “defendant was the killer in each murder.” Keeping the state’s articulated purpose and chain of reasoning for introducing the DNA evidence from all four crime scenes at the forefront and again applying requirements of the Oregon Evidence Code, the Supreme Court further held that the state, "stretching the doctrine of chances beyond its limits," failed to link its proposed use of the other crime scene evidence to the fact it wished to prove at trial in a way that did not rely on a prohibited “bad character” inference. Accordingly, the trial court’s order excluding the evidence was affirmed.
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