Smith v. State

Summary

The court held that Smith’s extraordinary motion for a new trial alleged facts that, if proved, could satisfy the requirements for relief based on newly discovered evidence. New expert analysis of existing medical records is not categorically excluded from consideration, and factual disputes about whether the analysis reflects post-trial scientific developments or could have been obtained earlier must be resolved at an evidentiary hearing. The court therefore vacated the denial of the motion and remanded for a hearing and reconsideration. No separate opinions were filed.