Blogs > Cliopatria > DNA and Durham's Ahab

May 14, 2006

DNA and Durham's Ahab




Flawed procedures often beget flawed results. The likelihood of the Duke lacrosse case confirming this maxim, indeed providing a record for future law students looking at how many procedural irregularities a prosecutor could commit in a single case, only continues to increase. In late April, Durham district attorney Mike Nifong requested that a court mandate all 46 white players on the Duke lacrosse team to give DNA samples. The filing cited the imperatives of clear-cut justice: “The DNA evidence requested will immediately rule out any innocent persons, and show conclusive evidence as to who the suspect(s) are in the alleged violent attack upon this victim.” A local court granted the order, even though Durham police appear to have made little effort to determine which of the 46 players even attended the party. Outside of Durham, people normally are not asked to give samples of their DNA based solely on their membership in a group.

Backlogs at DNA labs prevented the complete test results from arriving before his hotly contested May 2 primary, but Nifong indicted two players anyway—based on a photo array that ignored not one, but two, state guidelines. Yesterday, the final DNA tests arrived. They contained no match to either indicted player. (Since the attorney for one of the indicted players, Reade Seligmann, had released a time-stamped bank video showing Seligmann at an ATM machine at the time of the alleged rape, this news came as little surprise.) Given Nifong’s earlier assertion that DNA would “immediately rule out any innocent persons,” he might have struggled to get an indictment of Seligmann had he waited to present this evidence to the grand jury.

As to the other half of Nifong’s promise—that DNA would “show conclusive evidence as to who the suspect(s) are in the alleged violent attack upon this victim”—yesterday’s results yielded genetic material, obtained from a vaginal swab, from a single male source, proving that the accuser had sex before the rape exam occurred. But this DNA matched none of the 46 players. Instead, according to ABC News, it matched the accuser’s boyfriend. An AP wire story quotes Loyola Law School professor Stan Goldman, a frequent cable-news legal commentator, saying that this evidence should end the case, unless the district attorney possesses heretofore unrevealed testimony from an eyewitness to the alleged crime: “There has got to be some really good prosecution explanation as to why the DNA evidence does not exist and why someone else's would be there.” Since the accuser described a graphic and seemingly unprotected assault, it’s hard to see what this explanation would be.

But Goldman has probably underestimated Nifong, the Triangle’s equivalent of Ahab, searching for his version of the white whale—conviction of those he labeled “hooligans” in one of his 70-plus press appearances immediately following the alleged crime, appearances that seem to have violated North Carolina ethics guidelines regarding permissible public statements by prosecutors. Press reports from Raleigh suggest that Nifong plans to indict a third player, a resident of the house where the party occurred, on the grounds that DNA under one of the accuser’s fingernails, which were retrieved from the trash, might belong to the player. (There was no conclusive match one way or the other.) Given that the accuser claimed that her third attacker had a mustache (no players on the team had a mustache), a contradiction would seem to exist between the photo ID array used for the first two arrests and the justification for this arrest. But what’s one more contradiction in a case with so many?

Lest anyone think that he’s resting on his laurels with this new DNA evidence, Nifong showed otherwise. In what Chris Lawrence of Signifying Nothingtermed perhaps “the clumsiest effort at witness intimidation since, well, the last time Mike Nifong threatened someone involved with the case with something,” Durham police arrested cab driver Moezeldin Elmostafa on a 2.5-year-old misdemeanor warrant. A few weeks ago, an affidavit from Elmostafa provided the first glimpse of Seligmann’s alibi (that he wasn’t at the house at the time of the alleged rape). This alibi subsequently has been confirmed by the ATM video, cellphone records, various receipts, and an affidavit from the other passenger in the cab, lacrosse player Rob Wellington."The detective asked if I had anything new to say about the lacrosse case," the cabbie said."When I said no, they took me to the magistrate." Next week, we'll see Wellington hauled in on the basis of a complaint filed against him when he was in kindergarden.

Perhaps the arrest of Elmostafa will prompt Duke’s Group of 88 to reconsider their approach to the case, which heretofore has consisted of a commitment to “turning up the volume” and offering a public “thank you” to protesters who distributed “wanted” posters with photos of the lacrosse players around campus and banged pots and pans outside the residence of lacrosse players while shouting, “Time to confess.” The Bowen/Chambers report somewhat embarrassingly explained the professors’ position as based on the institution’s need to balance the due process protections of (white, male) Duke student-athletes with the fact that"in the eyes of some faculty and others concerned with the intersecting issues of race, class, gender, and respect for people, the Athletic Department, and Duke more generally, just didn't seem to 'get it.'" Yet as Elmostafa is a working-class African-American, presumably these “concerned” Duke faculty would feel no need to rationalize away authorities’ peculiar treatment of him. I’ll be checking future editions of the Duke Chronicle for a new “Group of 88” ad, saying they’re “listening” to those “concerned” about Elmostafa’s treatment.

Nifong, meanwhile, is rapidly achieving the apparently unachievable: overseeing an investigation that brings to mind the worst conduct of both sides in the Lewinsky affair. Like Ken Starr in decisions such as subpoenaing secret service agents, Nifong is so convinced of the moral guilt of his targets that he’s taken actions (such as arresting the cab driver) that only make him seem like an out-of-control prosecutor. And like Bill Clinton’s infamous “it depends on what the meaning of the word 'is' is” remark, Nifong has shown himself capable of the most tortured legalisms when new evidence has contradicted his earlier assertions (as when, responding to the Seligmann material contradicting the “timeline” of the alleged rape affirmed in the warrant authorizing the search of Seligmann’s dorm room, the district attorney replied that critics “don’t know what my timeline is.”) Indeed, this case is unlike any I can ever recall, in that in normal cases, such tortured explanations following release of unimpeachable evidence almost always come from the defense, not from the prosecution.

Explaining away the DNA results, however, will require more creativity than even Starr or Clinton ever demonstrated. But no one should doubt that Durham’s Ahab will be up to task. Perhaps he can allege a series of typos and/or proofreading errors in his April filing to the court. So, for instance, when he wrote, “The DNA evidence requested will immediately rule out any innocent persons,” he can now claim, at least with regard to Seligmann, “The DNA evidence requested will immediately rule in any innocent persons.” And when he asserted that an exact DNA match would “show conclusive evidence as to who the suspect(s) are in the alleged violent attack upon this victim,” he can now hold that he really meant it would “show conclusive evidence as to who the suspect(s) are not in the alleged violent attack upon this victim.” After all, he’s short-circuited virtually every other procedure in this case thus far, so why worry about an after-the-fact reinterpretation of a court filing?



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Stephan Xavier Reich - 11/25/2006

Where exactly does Chris Petit teach these "Rights" courses?


Robert KC Johnson - 5/15/2006

Only using it as an example of growing skepticism; I don't think it's a good idea, either, for exactly the reasons you mention. But coming from a Duke (law) faculty member and admitted strong Nifong supporter, the op-ed suggests that some at Duke are, perhaps, beginning to reconsider their initial approach to this case.


Oscar Chamberlain - 5/14/2006

Oh Lovely. Lie detectors are not nearly accurate enough to either confirm or deny her charges. They are only popular for in-house organizational questioning, and then largely because they intimidate.

KC do you support that solution, or are you simply using this as an example of growing skepticism?


Ralph E. Luker - 5/14/2006

Good question, Mr. Reich. Chris is located somewhere in southern Africa. Unfortunately, his comments verge on trolling, rather consistently, and he rarely bothers to read what anyone says in response to them. He claims to be a pacifist, but his style is to pop into a discussion, say something about as nasty as possible at considerable length, and disappear until the next time. I've found it unproductive to try to hold any conversation with him. KC is one of his favorite targets and he does love to tell historians that they are ignorant of the law. At one point, he asked to join Cliopatria. You cannot imagine my pleasure in having a moment of sanity in which I made a negative decision about that.


Jonathan Dresner - 5/14/2006

Why...oh why...since you don't listen to legal authorities or academics when they choose to comment at your blog...do you even bother with the pretense of having a legal discussion. If you want to learn something...ask...don't speculate.

They're our rights, too, Chris, and this is highly contested, historically contingent and -- your appeals to "pure universalism" aside -- capable of being affected by non-expert opinion. We let you talk about history; you let us talk about law. Free speech, freedom of inquiry, all that.


Robert KC Johnson - 5/14/2006

This weekend's Durham Sun features a column from Duke law professor Robinson Everett, who says that he "strongly supported" Nifong in the primary. Nonetheless, in light of the new evidence, he advises Nifong to ask the accuser to take a lie detector test; and if she fails or refuses to do so, to drop the case.
http://www.herald-sun.com/opinion/columnists/guests/68-734044.html


Robert KC Johnson - 5/14/2006

Ha :)


Robert KC Johnson - 5/14/2006

My comments about the DNA test itself have centered on its highly unusual nature. Indeed, the DA was able to persuade the court that he had probable cause to order the test. But there seems to have been very little attempt by the police to determine who was and was not at the party. In a more civil liberties-friendly environment--say, New York City--I rather doubt the DA would have been able to get a court order under such circumstances.

My concerns with the DNA order, however, have been twofold. First, having obtained this highly unusual order, the DA has proceeded to ignore his affirmation to the court on what the DNA would provide. I suspect that even the "masses of the great unwashed" could figure out that's going to pose a problem.

Second, if the suspects in this case were a predominantly African-American fraternity, I strongly suspect that the Duke faculty would have exhibited far greater concern with the civil liberties implications of the DA's action.


chris l pettit - 5/14/2006

have any of you been to law school? are you even legal historians?

Why...oh why...since you don't listen to legal authorities or academics when they choose to comment at your blog...do you even bother with the pretense of having a legal discussion. If you want to learn something...ask...don't speculate.

it is partly because of all the amateur legal experts in this country that it has become the monstrosity of the litigation culture that it is.

When I teach my rights theory course, we deal with the subject of mandated DNA samples...it goes hand in hand with the example of drug testing if you think about the general principle. The rules of evidence dictate that one needs probable cause to compel testing. Now, voluntary testing is a different story...but many legal authorities (including myself) still have a problem with that because of the fact that it can be manipulated in ways that question the constitutionality of the procedure. The fact that the court granted the mandate to test all the players without having reason to believe that they were at the party is highly dubious...and could definitely be challenged on appeal. There must be some evidence presented for EACH individual that places them at or near the vicinity of the incident for the court to even consider mandating testing.

Now...the complications start when all you have to go on is a bunch of heresay evidence...second hand accounts from eyewitnesses (many of whom were presumably intoxicated). You have to then look into a very delicate balancing test. If the circumstances are so muddled that it is impossible to get corresponding testimony regarding who was present and who was not (as it may be in this case), first, the prosecution is in a bit of trouble to begin with...but second, you have to then determine whether there is enough evidence/probable cause to mandate testing for an entire group or whether you just drop the testing (and most likely the case) all together. Ideologues such as KC immediately jump to option B...although they may not have any critically defensible reason for doing so (as Dr Luker has demonstrated). In this case, it seems as though one can place a significant percentage of the team at the house and the party...the party was a lacrosse function...there is enough circumstantial evidence to establish some sort of "minimum contacts" for several members of the team...there is evidence that other unidentified members of the team were present...and there is reason to believe that the team and those at the part will be unwilling or unable to provide a complete list of who was at the party.

When there are uncertainties such as those listed...the decisions rest with those who are trained in law...not historians or the masses of the great unwashed. All the amateur speculation is appreciated...but is sound and fury signifying nothing. If you want to take issue with the worthlessness of the judicial systems in this country, I am glad to have this discussion...I have written on it on several occasions...we have ideologically minded federal jurists who wouldn't know law if it hit them in the head because they are of the KC school of scholarship...the jury system is worthless since the first thing you learn in jury selection class is how to pick the whitest, least educated, most impressionable jury so as to turn the case into a theatrical contest between orators...our legal system is one of the worst in the world...it does not deal in the rule of law...it deals in the rule of man and rules. These are all valid criticisms. You are more than welcome to take issue with the system...but something tells me you would not want to really change it to be effective, but just to enforce the ideological position you find convenient...

CP


Jonathan Dresner - 5/14/2006

I don't suppose this discussion of broomhandles and bodily fluids is going to eventually come around to issues of handling historical evidence or theory in the academy, is it?


Robert KC Johnson - 5/14/2006

I agree completely that the AG should take over the case. I suspect that if that happened the charges would be dismissed, but if not, at least it would be competently prosecuted, preferably outside of Durham.

A prosecutor's press statements or the like aren't admissable--but the DNA assertion came in a formal court filing. As such, it's part of the record of the case.

I agree that the defense attorneys have been very aggressive, and effective, in public spin--but according to NC ethics guidelines, Nifong's previous public statements give the defense authority to respond. (I suspect that he now regrets giving the defense this opening.) And, there are certain things--such as the transcript of the photo array or the video of Seligmann at the ATM machine--that are hard evidence.


Ralph E. Luker - 5/14/2006

I may be wrong, but I don't think that a prosecutor's statements prior to trial are likely to be admissable as evidence if this case goes to trial. Attorneys for both sides in the case are guilty of massive spinning leaks in the case -- the defense more recently than the prosecution. That's all the more reason, I should think, that we may see an intervention, at least, for a change of venue.


Robert KC Johnson - 5/14/2006

On the broomhandle point, I'd agree with you completely, if there were any evidence of it. But, having looked through the entire transcript of the photo ID array, in which the accuser described the alleged attack, she never claimed to have been assaulted by a broomhandle or any other foreign object, though she described specifically what the three players allegedly did to her. I know that after the first DNA tests came back negative, her father went on TV to claim she was raped with a broom, and there were reports--which the accuser mentions in the photo array--of one of the players suggesting that the dancers use a broom in their performance, but I don't see how changing her story about the specifics of the attack itself will fly in this instance. It seems to me that Nifong is stuck with the description that the accuser offered in the photo array.

On the boyfriend's DNA, I agree completely in theory. (Obviously someone could have sex three days before a rape, for example.) The problem for Nifong, it seems to me, is his specific filing to get the DNA from the players--which contains no mention of an expectation of receiving a positive DNA match from the boyfriend. It simply says that a positive match will identify the perpatrator of the attack, while no match will show who's innocent. This ties in, as you know, to my overarching critique of this case--that the investigation has been rushed and procedurally irregular, and as a result, very poorly handled.

To me, the two most significant unanswered (and unanswerable) procedural irregularities in this case are (1) why Nifong chose to wait three weeks to run a photo ID and then blatantly ignored state guidelines when he finally did so; and (2) why he sought indictments before the DNA test results came in, even though he had assured the court that these results would clarify the innocent from the guilty. It's hard for me to see a reason other than a desire to get indictments, any indictments, before the primary, and worry about the consequences later.


Ralph E. Luker - 5/13/2006

I still have reservations about your reading of the situation, KC. You are working from the defense attorneys' reading and release of the evidence they have in hand. But the same news story that you're citing also pointed out that DNA samples may remain in the vagina up to six days after sexual intercourse, so a match to the accuser's boyfriend isn't nearly so damning to the prosecutor's case as you suggest; and, if there was a rape by broomhandle, as some of the lacrosse players seem to have suggested beforehand, there probably wouldn't be any DNA match to the lacrosse players. I agree with you that the latest news out of Durham doesn't sound like good news for the prosecutor, but in recent weeks he isn't the attorney who's been bending the ears of the journalists, so he may have more evidence in hand that he hasn't made public.