United States v. Graves
United States District Court for the Eastern District of Pennsylvania
465 F. Supp. 2d 450 (E.D. Pa. 2006)
Lacey Graves (defendant) was charged with armed robbery after investigators recovered an umbrella left at the crime scene and shoeprints matching sneakers later found at his girlfriend's house, along with a DNA sample from Graves himself. A DNA expert reported the odds of a random match to the umbrella DNA in the African American population were about one in two, while the odds of a random match to the DNA on the left and right sneakers were roughly one in 2,900 and one in 3,600 respectively. Graves did not challenge the DNA evidence's scientific reliability under Daubert, but argued under Federal Rule of Evidence 403 that the umbrella and sneaker DNA matches, given their high random-match probabilities, were more prejudicial than probative.
Whether DNA evidence with relatively low statistical significance may be admitted under Federal Rule of Evidence 403.