In a recent precedential opinion, the U.S. Court of Appeals for the Third Circuit concluded that reliable fingerprint evidence, standing alone, may be insufficient to support a criminal conviction.
The facts of the specific case were as follows. In 2003, the victim was opening the store where she worked in Pennsylvania when a masked man with a gun pushed his way inside and demanded money from the safes. After successfully receiving the cash therein—approximately $7,000—the robber fled, leaving behind a manila folder he had been carrying for reasons unknown. The victim described the perpetrator to police as approximately 5’10”, approximately 160 pounds, and with a voice that led her “to believe he could have been African American.”
What Led to the Ruling?
Two thumbprints recovered from the manila envelope were identified as belonging to Jamar Travillion, an African American man perhaps loosely fitting the physical description given at 6’1” and 170 pounds. Travillion was subsequently arrested, tried, and found guilty of the robbery in 2006. He appealed to the Superior Court of Pennsylvania, who rejected his claim that the evidence—the fingerprints—were insufficient to support his conviction. The Pennsylvania Supreme Court refused to hear his case and an unsuccessful petition for Post-Conviction Relief followed. In 2015, Travillion filed a habeas petition in the United States District Court, leading to this decision at the Third Circuit.
On the facts, the Third Circuit has held that no rational juror could find someone guilty of a crime, beyond a reasonable doubt, on the basis of these particular fingerprints. The court found it particularly persuasive that the fingerprints were found on an easily movable object, and there was no evidence as to the age of the fingerprints. Said the Court: “Although there is evidence that Travillion touched the folder at some indefinite time with his left hand, and there is evidence that the robber carried the folder at the time of the crime in his left hand, there is not sufficiently incriminating evidence that Travillion was the perpetrator holding the folder at the time of the crime.” The Court went on to find that the physical description of the robber “at best, merely does not exclude Travillion as the perpetrator” and was “insufficient additional incriminating evidence for any rational trier of fact to find Travillion guilty of being the robber beyond a reasonable doubt.”
Fingerprint Evidence, Alone, is Not Enough for a Conviction
Although the Court seemed to be parsing the facts pretty narrowly, the essential holding is that fingerprints alone are not enough to sustain a conviction. There needs to be something indicating, beyond a reasonable doubt, that the prints were actually impressed during the crime. The Court suggested that a very small additional quantum of evidence would be necessary to push this over the line—such as a connection to the getaway car used, ownership of clothing matching that used during the crime, or some more accurate physical description. Indeed, the Court seemed nearly to be admonishing the police and prosecution for failing to make or present such additional connections. Because Travillion is apparently serving an unrelated life sentence for a murder charge, this set of facts may have presented a unique opportunity for the Court to driving home this legal point.
But most importantly, this case demonstrates how smart and effective counsel can help change case outcomes. For nearly 15 years, every legal avenue was closed to Travillion when, in fact, his conviction was legally insufficient. If you have legal trouble, it is imperative that an experienced attorney review the specific facts of your case to determine its strengths, weaknesses, and to ensure that they are all presented in the best and most persuasive way possible. The attorneys at Dressel/Malikschmitt would love the opportunity to provide you with a free consultation to see how we may be able to improve your legal situation.
The above is general information only and is not to be relied upon as legal advice. It does not create an attorney client relationship nor should it be relied upon as advice in lieu of consultation with an attorney.