Thomas v. State
In a case of first impression in Florida, the Fourth DCA held that admission of DNA expert testimony using Bayes' Theorem—including a 'prior probability' of 50%—to calculate probability of paternity does not violate a defendant's presumption of innocence. The court expressly adopted the modern approach from Griffith v. State (Tex. App. 1998) and its progeny (Butcher, Jessop, Gonis), rejecting the older Skipper (Conn.) and Hartman (Wis.) line of cases relied on by the defendant.
Key facts
- Thomas was charged with sexual battery; the trial court admitted DNA expert testimony using Bayes' Theorem with a 50% prior probability to calculate the probability of paternity.
- The defendant challenged the admission of the Bayes' Theorem paternity evidence as violating his presumption of innocence, citing older Connecticut and Wisconsin cases.
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Why it matters
This is the first Florida appellate decision squarely addressing the admissibility of Bayes' Theorem-based paternity probability evidence in a criminal (sexual battery) prosecution, providing a citable framework for… — full analysis with a trial
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