STATEMENT OF FACTS - University of Illinois Springfield

Canine DNA
State’s Case-in-Chief
Forensic Evidence
Dr. Joyce Halverson conducted the DNA testing. Halverson’s qualifications
and the validity of using canine DNA forensically was examined at trial and
Halverson’s qualifications and methodology are extensively explored in the
argument portion of this brief. (Vol. LXIII, R. 2423-2535)
Halverson conducted DNA testing on the dog hair found on a piece of duct
tape used to seal one of the garbage bags containing a body part. One of the tests
was thrown out due to contamination. (Vol. LXIII, R. 2549) Based on her testing,
Halverson was able to exclude the smaller of the two dogs owned by Senior as the
donor of the dog hair found at the crime scene. (Vol. LXIII, R. 2551-60) The hair
from the larger dog matched at 5 loci showing six alleles with the reference
sample. The likelihood that the DNA found would randomly appear was 1 in
56,000. (Vol. LXIII, R. 2562-64)
On cross-examination, Halverson stated that each packet contained more
than one hair and the initial testing encountered some contamination. The
protocol is now to decontaminate the reference sample. (Vol. LXIII, R. 2566-77)
After the initial amplifications of the evidence sample, there were only four
scorable loci between the reference sample and the evidence sample. This would
be at the bottom rung of conclusions and is the minimum number of loci required
in California to make any conclusion as to a match. (Vol. LXIII, R. 2581-83) At
this point, when Halverson employed the product rule, she concluded that there
was a 1 in 2,694 chance of a random match between the evidence sample and
another dog. This conclusion did not take into account any potential lab error or
population subculture due to the fact the data base was exclusively pure bred
dogs from western United States. (Vol. LXIII, R. 2583-85) Halverson also did not
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