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Name: People v. Wilson
Case #: S130157
Court: CA Supreme Court
District CalSup
Opinion Date: 07/06/2006
Summary

A DNA comparison of appellant’s blood matched the blood at the crime scene in this murder case, and blood on appellant’s pants matched the victim’s. At trial, the prosecution presented evidence over defense objection which showed that only one Caucasian in 96 billion would match the crime scene blood, and the odds as to African-American and Hispanic populations were also presented. Appellant was convicted of murder. On appeal, he argued that the trial court erred because evidence regarding any particular population group is irrelevant absent independent evidence that the perpetrator was a member of that group. The Supreme Court affirmed, finding that the trial court correctly admitted the evidence. When the perpetrator’s race is unknown, the frequencies with which the matched profile occurs in various racial groups to which the perpetrator might belong are relevant for the purpose of ascertaining the rarity of the profile. As long as the data is not presented in a way which assumes that the race of the perpetrator is the same as that of the defendant, admission is not precluded. Here, no such assumptions were made, and the evidence was relevant, nonprejudicial, and properly received. The opinion specifically approved Pizarro I and II to the extent they condemn admission of evidence of the odds solely regarding the defendant’s population group. However, it disapproved Pizarro to the extent it concludes that evidence regarding any particular population group is inadmissible absent evidence that the perpetrator was a member of that group.