Conahan v. State
In an active death-warrant proceeding, the Florida Supreme Court affirmed summary denials of Conahan's third and fourth successive rule 3.851 motions and his rule 3.853 DNA-testing motion, denied a stay, and denied habeas relief. The Court held that newly commissioned expert reports and a new consensus study on forensic/medicolegal practice do not qualify as newly discovered evidence where the underlying facts were long available, and that speculative hopes of identifying a third-party DNA contributor fail rule 3.853's reasonable-probability standard.
Key facts
- Conahan, a death-row inmate, filed successive rule 3.851 postconviction motions and a rule 3.853 DNA-testing motion while under active death warrant.
- The trial court summarily denied all motions; Conahan argued newly commissioned expert reports re-analyzing autopsy, fiber, and paint evidence, along with new forensic-science consensus studies, constituted newly discovered evidence, and sought DNA testing on fingernail clippings and crime-scene debris to identify potential third-party contributors.
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Why it matters
This is the Court's most recent articulation of the limits on 'new science'/new-expert-report claims in successive capital postconviction litigation, extending Schwab and Sliney to consensus study reports and newly… — full analysis with a trial
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