Satterfield v. State

Summary

The Supreme Court of Maryland affirmed the denial of Satterfield’s petition for post-conviction DNA testing of a cigarette butt recovered near the crime scene. The Court held that the alleged testing results would not have a reasonable probability of producing exculpatory or mitigating evidence because the cigarette butt was not connected to the perpetrators or the instrumentalities of the crime, and a match to another woman would not tend to disprove Satterfield’s guilt. The Court also held that the circuit court could deny the petition without awaiting a response or conducting a hearing, and that remand was unnecessary despite the court’s failure to explain its ruling in writing.