EvidenceProf Blog

Editor: Colin Miller
Univ. of South Carolina School of Law

Monday, October 7, 2019

An Introduction to the Jonathan Irons Case & His Brady Claim Based on an Undisclosed Fingerprints Report

On June 30th, I read a New York Times article about WNBA player Maya Moore taking a one year leave of absence to work on the case of Jonathan Irons, who she believes was wrongfully convicted. I reached out to see if I could help, and I've been working on the case ever since for a future series on Undisclosed. That series will premiere next year, but this Wednesday, October 10th, Jonathan has a hearing on his petition for writ of habeas corpus that could decide whether his case moves forward. In this post, I will do a brief introduction to his case and highlight one of the issues he raises in his petition: an alleged Brady violation.

Jirons

Jonathan Irons

Very Brief Case Summary

On January 14, 1997, Stanley Stotler returned to his O’Fallon, Missouri home. after work After entering his bedroom, Stotler heard someone in his closet. The person in the closet ended up being a burglar who shot Stotler twice. O'Fallon police officers later determined that the burglar entered Stotler's residence through a basement window that the burglar broke and exited through the front door. Three latent fingerprints were lifted from the interior of the front storm door on Stotler's residence. Sixteen year-old Jonathan Irons was later arrested, prosecuted, and convicted of first degree assault, armed criminal action, and first degree burglary and given a sentence of fifty years.

Fingerprint Report

Before trial, the State disclosed to the defense a fingerprint report. In pertinent part, it reads as follows:

Screen Shot 2019-10-07 at 11.08.34 AM

Trial Testimony

At trial, Deputy Sheriff Ricky Luetkenhaus, who processed the crime scene, was the only witness who testified about the latent fingerprints. He testified as follows:

Screen Shot 2019-10-07 at 11.10.47 AM

The Second Fingerprint Report

A decade after the crime, in 2007, a team of advocates working for Irons inspected police reports from the O'Fallon Police Department and uncovered a second, previously undisclosed fingerprint report. In pertinent part, it reads as follows:

Screen Shot 2019-10-07 at 11.15.29 AM

In other words, the second fingerprint report reveals that (1) Stotler, the victim, was determined to be the source of one of the latent fingerprints lifted from the interior of the front storm door; and (2) both Stotler and Irons were excluded as the source of the other two latent fingerprints lifted from the interior of the front storm door.

The Brady Claim

The Supreme Court's opinion in Brady v. Maryland indicates that the State has an affirmative obligation under the Due Process Clause to timely disclose material exculpatory evidence to the defense. Evidence is "material" under this test when it undermines our confidence in the jury's verdict. Irons's Brady claim is fairly straightforward: The evidence against him was weak,* and this undisclosed fingerprint report was thus materially exculpatory.

Namely, without the report, the defense thought that Stotler was determined to be the source of all of the latent fingerprints lifted from the interior of the front storm door. On the other hand, if the State had disclosed the second fingerprint report at/before trial, the defense would have realized that Stotler was excluded as the source of two of the three latent fingerprints lifted from the interior of the front storm door. With this second report, the defense thus could have argued that (1) it is highly likely the burglar was the source of the other two latent fingerprints; and (2) Irons was not the source of those two latent fingerprints (as revealed by both reports); and (3) Irons was therefore not the burglar.

The State's Response

So, how has the State responded to this argument? In two ways. First, it has claimed that

A detective testified that the only prints which could be identified upon examination were identified as belonging to the victim....This is the same information that was provided in the allegedly undisclosed report. Therefore, based on the detective’s testimony, Irons should have been aware of his claim that there was an undisclosed fingerprint report at the time of trial, and he cannot show cause now.

Initially, it is unclear whether this is true. Unfortunately, on many occasions forensic work is performed without a report. Therefore, the fact that the detective gave this testimony does not necessarily mean that a second report was prepared. Moreover, and more importantly, the question is not whether the detective's testimony gave notice to the defense of a undisclosed report; the question is whether that testimony gave the defense notice of an undisclosed AND MATERIALLY EXCULPATORY fingerprints report.

And the answer is that it did not. The first fingerprint report excluded Irons as the source of the three latent fingerprints lifted from the interior of the front storm door. Deputy Luetkenhaus's testimony made it look like Stotler was determined to be the source of all of the latent fingerprints lifted from the interior of the front storm door and that there were no "other usable prints." Even if this testimony alluded to a second fingerprints report, it did NOT allude to that report being materially exculpatory. Instead, this testimony made it look like Stotler was the source of all of the fingerprints and that the burglar, whether that be Irons or someone else, did not leave behind any fingerprints.

The reason the second report is material and exculpatory is because it shows that Deputy Luetkenhaus was wrong. He was able to get two usable prints from the interior of the front storm door that were not identified as Stotler's prints. And, if those prints were left by the burglar, as seems likely, then Jonathan Irons is innocent.

The State's second claim is that 

Irons could not have been disadvantaged during trial if he did not possess the report because the allegedly undisclosed report stated that the victim’s fingerprint was identified at the crime scene....This information would not have supported an alternate perpetrator defense.

This argument entirely misses the point. The point is not that Stotler was determined to be the source of one latent fingerprint lifted from the interior of the front storm door. The point is that Stotler was determined to be the source of ONLY one latent fingerprint lifted from the interior of the front storm door, meaning that neither he nor Irons was the source of the other two latent fingerprints. Therefore, Stotler being the source of ONLY one latent fingerprint does support an alternate perpetrator defense because it means that the other two fingerprints could have come from an alternate perpetrator

_______________

*I'll go into more detail on the evidence against Irons on Undisclosed and/or future blog posts. 

-CM

https://lawprofessors.typepad.com/evidenceprof/2019/10/on-june-30th-i-read-a-new-york-times-article-about-wnba-player-maya-moore-taking-a-one-year-leave-of-absence-to-work-on-the.html

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Comments

Based on everything available online, it's more than likely he committed this crime. However, he served enough time and should be out. It's very telling that the keywords that keep being used are "wrongfully convicted" and not innocent. Maybe the podcast will show something different but as of now, there are way too many coincidences to show he did do it rather than he didn't.

Posted by: Roger | Nov 4, 2019 9:45:51 AM

Interesting. So, I i understand this correctly.....Iron's finger prints were not found at the victims home. What other evidence was presented for his conviction?

Posted by: Jon | Jan 22, 2020 2:59:43 PM

This argument entirely misses the point. The point is not that Stotler was determined to be the source of one latent fingerprint lifted from the interior of the front storm door. The point is that Stotler was determined to be the source of ONLY one latent fingerprint lifted from the interior of the front storm door, meaning that neither he nor Irons was the source of the other two latent fingerprints.

But he was there... period because his fingerprint was there.. weather it was one source or two.

I defend people who are wrongly convicted.. but you are a "Professor of Law" no wonder this case has gone no where.

Posted by: Joseph Crenshaw | Jan 22, 2020 9:26:57 PM

THIS, is you argument?

So the prints had no bearing to the defendents guilt or innocence. As stated by the deputy in the trial, none of Mr Irons fingerprints were found...who cares if they were smudged and unintelligible, smudged fingerprints are useless to a jury as they could be anybodies, including the victim or the perp.

This is arguing over semantics, the State is right, this "new information" would change nothing in front of same or different jury. It is clear other factors OTHER than fingerprints led to his being found guilty.

Posted by: Jesse | Jan 23, 2020 10:46:40 AM

Roger: What is the evidence of guilt that you’ve seen?

Jon: Primarily the identification by the victim, but there were serious problems with that ID.

Joseph Crenshaw: Stotler was the victim. Irons was the defendant. This Is saying that one of the three fingerprints at the likely point of entry came from Stotler while the other two came from neither Stotler nor Irons, meaning that they likely came from the true perpetrator.

Jesse: Why would you say they have no bearing? The authorities thought the fingerprints were likely left at the point of entry by the perpetrator…and the fingerprints weren’t Irons’s fingerprints.

Posted by: Colin Miller | Feb 29, 2020 5:16:43 AM

So, I've read the advocacy website and the scribd documents that come up when Googling this case. Jonathan Irons's story does not add up. He was in the neighborhood and by the house brandishing a gun according to his FRIENDS but he didn't do this? There are no other suspects but him? No one else has come forward? He wasn't running from the cops but they found him in a small town where he went to sell drugs but he didn't go to St. Louis to sell? He cried when the police roughed him up but he fought off and stole a gun from someone trying to rob him while dealing drugs?
It seems like everything said is manipulated to make him look like he was a bad kid but not that bad.

Posted by: Martin Lewis | Mar 2, 2020 10:31:08 AM

Usually the Undisclosed Podcast gets it pretty right, that doesn't seem to be the case with this one. No one else came forward to take responsibility for the crime? There were multiple witnesses and friends of his who testified against him? He had a gun he was showing off to these friends? Are there a lot of black teenagers showing off guns in this neighborhood? Was it commonplace? No one else saw another black person with a gun around? Not one description of even an alternative suspect?

Posted by: Peter | Mar 6, 2020 7:59:44 PM

Colin, overturning a conviction is not the same as being exonerated. You know this. You said you've seen thousands of pages of his case. Where? What was enough for you to overlook his inconsistencies?

Posted by: Peter | Mar 9, 2020 3:49:35 PM

Excuse me, overturning a conviction is not the same as being innocent.

Posted by: Peter | Mar 9, 2020 3:51:12 PM

Peter: An exoneration generally means that a conviction for a crime is reversed, either through demonstration of innocence, a flaw in the conviction, or otherwise. That's exactly what happens today. If the State appeals or decides to re-prosecute, we'll all of the aspects of the case on the podcast. If not, we might still do a retrospective.

Posted by: Colin Miller | Mar 9, 2020 4:52:57 PM

Thanks Colin. If it comes down to it, please go into detail about what you've seen that's not available online. A flaw in the conviction is one thing. But what his advocacy team put online does not amount to innocence. What about justice for the man who was shot? Was there another suspect that wasn't introduced at the original trial?

Posted by: Peter | Mar 9, 2020 5:03:13 PM

Peter: From your prior comment, it sounds like you've listened to Undisclosed before. If so, you probably know that we like to cover things on the podcast that weren't previously public. If and when we cover the case, you'll hear more than what's currently available. Thanks.

Posted by: Colin Miller | Mar 9, 2020 5:06:35 PM

He is COMPLETELY innocent! There's no way to obtain a conviction without any DNA evidence to back it up. The State lied from the very beginning, and knowingly withheld evidence because they didn't have a case. Prosecutorial misconduct at it's best! I'm glad the judge saw right through the State's lies and did the right thing. He never should've been in prison in the first place.

Posted by: Donald Alexander | Mar 14, 2020 2:00:11 PM

Thank you to everybody that was a part of this case. This young man went to school with my daughter and I can't imagine losing this much of my life over something that was so messed up. I truly believe in the Innocence foundation and the foundation that Maya set up. It's an uphill battle and the battle was worth it thank you again to all who worked to vindicate Jonathan irons

Posted by: Sandra Briggs | Mar 14, 2020 6:13:10 PM

Thank you to all who worked on Jonathan's case. He was a student at the high school where my daughter went and they were in the same class to graduate together. I can't imagine losing this much of my life over first of all if really he did a breaking-and-entering 50 years is ridiculous but two have been wrongfully accused of all that happened afterwards is just incomprehensible. Thank you to Maya for all of her work and everyone else that listen to her and went forward to prove this young man innocent of the charges.

Posted by: Sandra Briggs | Mar 14, 2020 6:14:42 PM

Thank you for all the people involved oh, but how unfortunate that we won't have all of those people at the different trials around the world for people who have been wrongly convicted what a wonderful day today that a woman had to take the steps of putting her money where her mouth is and do what are Brie person should be willing to do to help, the people who were supposed to look out for this man's right, who took an oath to uphold Justice and this country that they fought and is still fighting to be free in that is a shame a man have lost many years of his life because someone chose not to tell the truth and it took relatively a small amount of time to do, if they would have done it but they took a oath to stand up for what was right and it has failed miserably thank you again for all those individuals who was involved with this situation unfortunately there is not enough of you all to go around today I am so happy to be not only a black African woman but I'm living in America where it has been sworn to me but I will get Justice and again unfortunately we never have thank you again

Posted by: Cfm | Jun 19, 2020 6:30:08 AM

Im confused. Whos fingerprint is on the door? And why cant they simply reprint victim and accused if there is confusion?

Posted by: SS | Jul 2, 2020 4:09:49 PM

I am confused as to what the second (hidden?) report stated. I don't think either report matched the defendant's prints, so how did it have any bearing on his innocence. Stating that the identified prints show a different perpetrator is a huge leap. It could have been a relative, the mailman, the paperboy, etc.. Was there any other evidence of the defendant being in the house? Seems odd that they didn't find any other prints.

Posted by: SJ | Aug 8, 2020 10:58:20 AM

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