McCrory v. Alabama
Headline: Court declines to review a 1985 murder conviction tied to discredited bitemark science, leaving the conviction intact while urging states and Congress to create postconviction remedies for wrongly convicted people.
Holding: The Court denied review of a 1985 conviction based on now-repudiated bitemark testimony, leaving state-court rulings intact while Justice Sotomayor urged legislative remedies for convictions tainted by faulty forensic science.
- Leaves McCrory’s 1985 conviction in place while review is denied.
- Encourages states and Congress to create postconviction paths for discredited forensic evidence.
- Signals federal habeas review may be difficult; state statutes can offer faster relief.
Summary
Background
Charles McCrory was convicted of murdering his wife in 1985 after a famous forensic dentist testified that marks on the victim matched McCrory’s teeth. That expert later recanted, and scientific reports have concluded bitemark analysis lacks a reliable scientific basis. McCrory filed state postconviction petitions in 2002 and 2020; a state court held a hearing but denied relief, and the Alabama Court of Criminal Appeals affirmed. McCrory then asked this Court to review his constitutional claim.
Reasoning
The core question is whether a conviction based on expert evidence later repudiated by the scientific community is so unfair that it violates the Due Process Clause. Justice Sotomayor explained that bitemark analysis has been discredited by major scientific reports and that ordinary state and federal procedures can leave people without an effective path to relief. She noted procedural hurdles in state statutes and in federal habeas review after AEDPA, and she described how some States have adopted targeted postconviction laws to address changed science. Because these constitutional questions have not yet percolated through the lower courts, she voted to deny review while urging legislative solutions.
Real world impact
The denial leaves McCrory’s conviction in place for now, but the statement highlights a broader problem: many convictions rely on forensic methods now questioned by scientists. Justice Sotomayor pointed to at least six States that have created statutory paths to reexamine convictions affected by changed science, and she urged other legislatures and Congress to act rather than wait for this Court to decide the constitutional issue.
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