Can Court Deny a Motion to Have Blood-Stains Subjected to DNA Testing ?
In People v. Savory, 197 Ill. 2d 203, 208, 756 N.E.2d 804, 808, 258 Ill. Dec. 530 (2001), the defendant was convicted of the stabbing deaths of a brother and sister. Savory, 197 Ill. 2d at 205, 756 N.E.2d at 806.
The trial court denied the defendant's section 116-3 motion to have bloodstained trousers, which the State alleged the defendant wore during the commission of the crimes, subjected to DNA testing. Savory, 197 Ill. 2d at 208-09, 756 N.E.2d at 808.
The supreme court affirmed, finding the evidence the defendant sought to test was not materially relevant to his claim of actual innocence. Savory, 197 Ill. 2d at 214, 756 N.E.2d at 811.
The court reasoned testimony regarding the source of the bloodstain on the trousers was a collateral issue at the defendant's trial and not central to the State's evidence of guilt. Savory, 197 Ill. 2d at 215, 756 N.E.2d at 811.
It concluded a greater part of the State's case concerned the defendant's knowledge of the crime scene and his inculpatory statements to others hours after the crimes were committed. Savory, 197 Ill. 2d at 215, 756 N.E.2d at 811.
Further, the court concluded even a test result in the defendant's favor would not significantly advance his claims of innocence and would only exclude one minor item from evidence of guilt. Savory, 197 Ill. 2d at 215, 756 N.E.2d at 811-12.