Rosten Lee Clark, Petitioner v. the People of the State of Colorado, Respondent

Summary

The Supreme Court of Colorado granted certiorari to decide whether DNA evidence linking Clark to the crime scene, together with circumstantial proof, sufficiently identified him as the perpetrator of a 2004 sexual assault. Rejecting the court of appeals' adaptation of the Silva/Ray fingerprint-identification test—which would have required corroborating circumstances excluding deposition of the DNA at some other time—the court held that the Bennett substantial evidence test governs, and that the prosecution need not exclude every reasonable hypothesis of innocence or disprove the defense's alternative explanations. Viewing the DNA on a jacket purchased two days before the assault together with the height, clothing, familiarity, and disability-awareness evidence in the light most favorable to the prosecution, the court found the evidence sufficient and affirmed the court of appeals' judgment affirming the conviction, while expressly disapproving its rationale.