State of Tennessee v. Randall Scott

Summary

The Tennessee Supreme Court reversed Randall Scott's convictions for rape of a child and aggravated sexual battery because the trial court improperly denied his request for state-funded expert assistance in DNA analysis despite his particularized need, an error the Court could not call harmless beyond a reasonable doubt given that DNA evidence was the keystone of the State's identification case. The Court held that no pretrial hearing on the general reliability of mitochondrial DNA analysis was required because the DNA admissibility statute deems such analysis trustworthy and reliable, while separately holding that the State failed to establish the chain of custody for hairs that were mounted on microscope slides. The case was remanded for a new trial on both counts.