In People v. Wakefield, the Court of Appeals recently addressed the admissibility of expert scientific DNA evidence that is based on complex computer analysis and the discoverability of the computer source code underlying that analysis. The court found that the trial court had properly admitted DNA evidence generated by the TrueAllele Casework System (TrueAllele) even though the defense had not been provided with the underlying source code for the software utilized by TrueAllele.

The case involved a victim who was found dead in his apartment on April 12, 2010. After the victim missed a scheduled appointment and was unreachable, a case worker from a mental health services organization came to the victim’s apartment to perform a welfare check. The victim was discovered with a guitar amplifier cord wrapped around his neck. There was no sign of forced entry, evidence that a struggle had taken place or indication that his death was a suicide. Several items, including a PlayStation video game, a laptop computer and a distinctive orange duffel bag were missing from the victim’s apartment. Witnesses had seen the defendant in the victim’s company that weekend and the defendant admitted to three people that he had choked the victim. Another witness saw the defendant with an orange duffel bag similar to the one stolen from the victim’s apartment while the defendant was attempting to trade a PlayStation and a laptop for drugs. The victim’s Play Station was later recovered from the home of a local drug dealer.