The Case of Humberto Leal García: an Overview
In the United States, Article 36 of the Vienna Convention on Consular Relations is a crucial complement to the due process rights already enshrined in state and federal law. Without its protections, a trial that is supposed to be “free and fair” may be neither of those things. For a foreign national charged with a capital offense, violation of the fundamental rights enshrined in Article 36 can be a matter of life or death. Such was the case for Humberto Leal.
Humberto Leal García, a Mexican national with no prior criminal convictions, was arrested for capital murder, tried, and sentenced to death without ever learning that he had a right to consular assistance. Before his arrest, Mr. Leal lived in a poverty- stricken area of San Antonio with parents who had immigrated to the United States from Mexico to make a better life for themselves and their children. He suffered from brain damage and learning disabilities. He had no understanding of the law, few resources to hire an attorney, and no knowledge of what evidence he needed to prove his innocence of capital murder charges. By all accounts, Mr. Leal was precisely the sort of person Article 36 of the Vienna Convention was meant to protect. However, no one in the criminal justice system ever informed Mr. Leal of that he had a right to speak with consular officials, or that the Mexican government could aid in his defense. It was not until Mr. Leal reached death row that he received the address of his consulate—from another inmate.
Without the Article 36 protections he was entitled to as a matter of law, Humberto Leal received disgracefully inadequate representation during his pre-trial, trial, sentencing and appellate proceedings. One of his trial attorneys has twice been suspended from the practice of law as a result of ethical violations. Mr. Leal was convicted on the basis of junk “bite mark” science, later discredited throughout the legal system, and patently unreliable forensic evidence. During his sentencing, which lasted only a single day, Mr. Leal’s attorneys failed to present any of the profoundly mitigating evidence that later came to light with the assistance of the Mexican government. The jury that sentenced Mr. Leal to death never learned that he was the victim of horrific sexual abuse by his parish priest, which had severe and lasting effects. Jurors never realized that Mr. Leal had struggled to overcome learning disabilities and frontal lobe brain damage, and spent his childhood dodging neighborhood gangs and beatings from his parents. Nor did they learn that, in spite of these disadvantages, Mr. Leal was gainfully employed, devoted to his younger brothers and sisters, and the first in his family to graduate from high school. Based on the distorted, incomplete picture of Mr. Leal provided by the prosecution, he never stood a chance.
International tribunals, including the International Court of Justice and the Inter-American Commission on Human Rights, found that the United States breached Mr. Leal’s Vienna Convention rights, as well as his right to a fair trial and competent legal representation. Both of these bodies also found that Mr. Leal is entitled to review and reconsideration of his conviction and sentence, and that executing Mr. Leal before he receives this remedy would be a gross violation of international law. The Inter-American Commission further concluded that the violations of his rights were so prejudicial that he is entitled to a new trial. Both Republican and Democratic Presidents agree that Mr. Leal is entitled to the review and reconsideration of his conviction and sentence prescribed by the International Court of Justice, and Congress is moving steadily toward the passage of legislation that would cement this right as a matter of federal law.
The violation of Humberto Leal’s consular rights deprived him of a fair trial.
There can be little doubt that if the government of Mexico had been allowed access to Mr. Leal in a timely manner, he would not now be facing execution for a capital murder he did not commit. Mexico has had an extensive program for monitoring and providing assistance to its citizens facing the death penalty in the United States since the late 1980s. Officials from the Mexican Foreign Ministry receive special training to assist Mexican nationals that are indigent, or that suffer from cognitive impairments and other disabilities. Consular officials routinely monitor defense counsel, confer with the defendant and his family, attend court proceedings, and assist with funding for investigators and experts.
Upon learning of Mr. Leal’s case, the Mexican government retained counsel to assist his post-conviction lawyers. Mexico’s bilingual retained lawyers have sought access to DNA evidence to challenge his culpability, have undertaken a comprehensive investigation of his life history, and have worked closely with his family members, the consulate, and others to challenge his conviction and sentence. Unfortunately, Mexico’s assistance came too late to affect the result of Mr. Leal’s capital murder prosecution. If the Mexican Consulate had known of Mr. Leal’s detention at the time of his capital murder trial, it could have assisted the defense investigation, especially in Mexico; provided funds for experienced investigators and mental health experts; assisted in bringing about a possible plea bargain; monitored counsel, and taken measures to ensure Mr. Leal was represented by competent counsel.
Instead of the comprehensive defense the Mexican government would have provided, Mr. Leal received grossly incompetent representation. One of his appointed lawyers, Jose M. Guerrero, has twice been suspended from the practice of law and was publicly reprimanded on two other occasions for failing to carry out his obligations to clients. Review of Mr. Leal’s trial transcript reveals an appalling lack of preparation by trial counsel. The defense failed to conduct independent investigations of forensic evidence, introduce their own expert witnesses or even to cross-examine crucial prosecution witnesses, leaving the state’s unreliable forensic evidence uncontested. Nor did counsel for Mr. Leal effectively challenge the serology, DNA and bite mark evidence on which the prosecution’s case depended. The complete failure of Mr. Leal’s attorneys to represent their client in any meaningful way deprived him of his chance for a fair trial.
The Culpability Phase
Mr. Leal was accused of the rape and murder of Adria Sauceda in 1994. In order to convict Humberto Leal of capital murder, the prosecution had to prove that Mr. Leal kidnapped and sexually assaulted Adria Sauceda before she died—accusations Mr. Leal vehemently denies.
Evidence introduced by the prosecution at trial established that Ms. Sauceda was sexually assaulted by several men at a party on the night of her death. |1| The prosecution did not accuse Mr. Leal of participating in those earlier rapes. Although the police found semen in the victim’s rectum, they never conducted DNA testing to identify the donor of the semen, nor did prosecutors ever charge any of the rapists with a criminal offense. Mr. Leal was last seen leaving the party with the victim to take her home.
Mr. Leal later told the police that he had argued with Ms. Sauceda and pushed her down, injuring her. He stated that he had panicked when he realized that he had injured her, and fled the scene. He adamantly denied sexually assaulting Ms. Sauceda.
Ms. Sauceda’s body was found approximately 100 yards from the house where the she had been raped earlier that evening. She had been sexually assaulted with a stick, and was killed with a rock found in close proximity to her body. Around the time her body was discovered, prosecution witnesses testified that two men from the party were seen with the victim’s purse. They scattered the contents and threw it into a tree before the police arrived.
The state relied on two pieces of evidence in arguing that Mr. Leal kidnapped Adria Sauceda. First, the state argued that Luminol testing revealed the presence of Ms. Sauceda’s blood in Mr. Leal’s car. The state concluded that this signified that Ms. Sauceda struggled to get away, and was being taken without her consent. Second, the state argued that because the location of the victim’s body was not en route to her house, Mr. Leal must have taken her to the location against her will.
Inexcusably, Mr. Leal’s defense counsel failed to object to the state’s preposterous claim that Luminol testing had revealed the presence of the victim’s blood. It is well established that Luminol cannot distinguish between animal blood and human blood, and also reacts to substances that are not blood at all—such as soils, detergents, bleaches, carpet, metal objects, tools, plastic panels, wood, and vegetable compounds. Luminol testing is so unreliable, and can be so misleading to the jury, that courts frequently exclude the results of Luminol testing unless additional, confirmatory tests have been done to determine the presence of human blood. Yet in this case no confirmatory tests were done, in spite of the fact that there was no blood found on Mr. Leal’s jeans or on his boots, socks, red T-shirt, or on the floor mats of the car. |2| Nonetheless, the state was allowed to argue in summation to the jury not only that Ms. Sauceda’s blood was discovered in Mr. Leal’s car, but that attempts had been made “by the defendant and/or his family” to wipe it up, so that “you would not see it,” thus proving kidnapping. |3| The evidence supported neither assertion.
Nor is there evidence that Mr. Leal drove Ms. Sauceda anywhere against her will. She was seen “willingly” entering his car. |4| One witness testified that he heard her giggling when she entered Mr. Leal García’s car. |5| The court recognized that the state’s evidence was weak – so weak that it hesitated to instruct the jury on the charge of kidnapping. |6| There was simply no reliable evidence to prove that a kidnapping occurred.
Neither was there any conclusive forensic evidence proving that Mr. Leal sexually assaulted Ms. Sauceda. This lack of evidence is even more problematic for the state in light of the testimony of the state’s own witnesses, who stated that several men had sexually assaulted the victim on the night of her death. |7| Thus, to convince the jury that Mr. Leal sexually assaulted the victim, the state relied heavily on the testimony of Megan Clement, a DNA expert employed by LabCorp, who concluded that the victim was a “possible donor” of the “very minute” blood spots discovered on Mr. Leal’s underwear. |8|
In a sworn affidavit, Dr. Elizabeth Johnson, a forensic scientist formerly with the Harris County Medical Examiner’s Office, concluded that the protocol followed by Ms. Clement was deeply flawed and that her testimony was highly misleading. Most important, LabCorp’s results did not establish to any degree of certainty that Adria Sauceda’s blood was on Mr. Leal’s underwear. The now outmoded technology LabCorp used “gave results such that no one in the population could be eliminated as a contributor of the DNA detected at four of the five loci tested.” In light of these flaws, Dr. Johnson recommended re-testing of the biological material found on Mr. Leal’s underwear. Current technology would permit an accurate analysis of the blood found on Mr. Leal’s underwear in order to exclude the victim as a donor and undercut the only rational basis for the jury’s capital verdict. Mr. Leal is currently seeking access to the underwear in order to subject it to new testing.
The prosecution’s mischaracterization of the bloodstain evidence in this case was pivotal to Mr. Leal’s conviction for capital murder. Had the reliability of that evidence been challenged by the defense—as it should have been—it is more likely than not that at least one juror would have voted to acquit Humberto Leal of capital murder. Instead, Mr. Leal’s attorneys failed to consult their own expert and therefore failed to expose the flaws in Clement’s testimony. In fact, the state had entirely failed to prove that the stains in question came from the victim’s blood: as the Texas Court of Criminal Appeals has since recognized, “with the science available at the time of trial in 1994, no one could credibly say that an unknown blood sample came from a given individual”. |9|
The state’s bite-mark evidence was equally unreliable. At trial, the state produced a so-called “bite-mark expert” to support its contention that Mr. Leal had assaulted the victim. The state’s witness testified that Mr. Leal’s teeth had a unique pattern consistent with one of the bite marks found on the victim’s body. |10| But there is overwhelming evidence that bite-mark comparisons of this kind are junk science. A 1999 study involving members of the American Board of Forensic Odontology resulted in 63.5% false positives when experts attempted to match four bite-marks to seven dental models. |11| In 2009, a congressionally mandated report from the National Research Council of the National Academy of Sciences found serious deficiencies in bite-mark evidence, including flaws that directly invalidate the findings of the state’s expert. |12| The report found “no evidence of an existing scientific basis for identifying an individual to the exclusion of all others.” |13| The report also found that “[i]n numerous instances, experts diverge widely in their evaluations of the same bite mark evidence,” and that there is no scientific evidence that the various methods used by bite mark experts are reproducible. |14| Finally, studies of bite mark analysis in controlled tests have shown “widely differing results and a high percentage of false positive matches.” |15|
This evidence casts serious doubt on Mr. Leal’s guilt of capital murder. The jury that sentenced Mr. Leal heard gross misrepresentations of forensic evidence and was deprived of the opportunity to consider powerful rebuttal evidence.
The Penalty Phase
The prosecution’s mischaracterization of facts continued into Mr. Leal’s sentencing, where the state’s main aggravating evidence was an alleged prior sexual assault for which Mr. Leal was never arrested or charged. As noted by the Inter-American Commission on Human Rights, “using evidence of unadjudicated crimes in this manner is, effectively to presume the defendant’s guilt and impose punishment . . . through a sentencing hearing rather than a proper and fair trial process accompanied by all of the substantive and procedural protections necessary for determining individual criminal responsibility.” |16| The Inter-American Commission on Human Rights found that use of this unadjudicated offense during the punishment phase of Mr. Leal’s trial violated his rights to fair trial and due process under the American Declaration.
Furthermore, the State’s other significant penalty-phase witness, Hoyt Garner, has since been discredited by his colleagues at South San Antonio High School. Mr. Garner, a former vice-principal, testified that in his opinion Mr. Leal had “no respect for authority” and would never change. |17| However, Mr. Garner has been described as “the most unprofessional teacher” by his colleagues and was known for being physically rough with students. |18| Other teachers and school staff did not share Mr. Garner’s opinions of Humberto Leal. Mr. Calhoun, who later served as vice principal of Mr. Leal’s high school, stated that he would have testified in Mr. Leal’s favor if asked. |19| However, Mr. Leal’s trial attorneys failed to contact any of his teachers to ask them to testify on Mr. Leal’s behalf, and the jury never heard any of the evidence of Mr. Leal’s positive achievements and relationships with teachers in high school.
Humberto Leal’s background made him particularly vulnerable to the violations of his consular rights by Texas authorities—and to the failure of his trial attorneys to provide him with even a minimally competent defense against the charges of the state. Humberto had no experience with the justice system in the United States. He had never been arrested, charged, or prosecuted for any crime prior to his arrest for Ms. Sauceda’s murder. He came from a low-income, predominantly Spanish-speaking family. He suffered from mental disabilities that impeded his ability to learn, and neurological damage that impaired his judgment. Yet prior to his sentencing, his attorneys neglected to conduct even the most basic inquiries into Humberto’s life history. The jury that sentenced Mr. Leal to death did so without the opportunity to consider any of the compelling and profoundly humanizing evidence that later came to light as a result of Mexican consular involvement. In fact, the entire penalty-phase hearing, the jury’s sentencing determination and the formal sentencing were all completed in a single day.
Both of Humberto’s parents grew up in slums outside of Monterrey, Mexico and were brought up in homes where domestic violence was an accepted part of life. Humberto’s mother, Francisca, and her six siblings were raised on a meager diet of soup and beans in a one-room home. Francisca’s father was murdered in jail when Francisca was seven. Francisca’s mother would beat the children violently with a belt when she was angry. Francisca met Humberto’s father, Humberto Sr., when she was fourteen years old. Although Humberto Sr. came from a family that was even more impoverished than her own, Francisca ran away to marry him when she was just sixteen in order to escape her abusive mother. Unfortunately, Humberto Sr. was also extremely violent towards Francisca, especially when intoxicated, and would beat her once a week throughout their marriage.
Francisca became pregnant with Humberto, her second child, when she was only 18 years old. Due to the family’s poverty, Francisca had very little to eat while she was carrying Humberto. Malnutrition may have been a factor in Humberto’s slow childhood development; Francisca recalls that he began walking and talking later than other children. When Humberto was one and a half years old, the family moved to San Antonio, Texas. Humberto Sr. spent all his time working as a mechanic to provide for his family, and left the child-rearing responsibilities to Francisca. Francisca was young and felt isolated in a foreign country where she did not speak the language. With no outside guidance on childrearing, Francisca fell into old patterns of abuse with her own children, beating Humberto and his older sister Nancy with a belt. On one occasion, she tied Nancy and Humberto to a tree by their legs and hit them when they tried to escape. Francisca and Humberto Sr. also fought frequently in front of the children. Once, when Humberto tried to protect Francisca from his father, Humberto Sr. beat Humberto so hard that Francisca called the police. Neighbors report frequently seeing Humberto Sr. drunk.
Francisca’s isolation from the community and embarrassment over her inability to speak English directly affected Humberto’s education. As a child, he was required to repeat the first, third, fifth, sixth, and ninth grades. When he was in second grade his teachers suspected he had serious learning disabilities and recommended him for special education. However, because Humberto’s parents refused to grant permission, his teachers were unable to test him and place him in special education. Humberto also had a hard time socially in elementary school. According to his brother Wally, who is one year younger than Humberto, neighborhood children often mocked him for his strange name, appearance (one of Humberto’s eyes appears lower than the other), gait (Humberto fell down a flight of stairs when he was four and had reconstructive foot surgery that required him to wear special shoes), and for being “slow.”
To find a safe haven from the violence at home and in his neighborhood, Humberto sought refuge in the church. He took communion classes at St. Clare church, where the nuns would frequently scold him for misbehaving in class. As punishment, he was sent to Father Federico Fernandez, the parish priest. Had the sisters known the sort of punishment that Father Fernandez inflicted, they never would have allowed young Humberto to stray into his clutches.
Dr. David Lisak, a clinical psychologist and expert in the field of male sexual abuse, has examined Mr. Leal and recounted the series of events that culminated in the anal rape of Humberto Leal when he was only in fifth grade. Dr. Lisak reports:
Mr. Garcia described various incidents that occurred during these “punishments” that are entirely consistent with how child abusers groom their victims. For example, Mr. Garcia described how the priest would approach him from behind while he was bent over cleaning the pews. At first he would “accidentally” bump into Mr. Garcia, always touching him somewhere near his buttocks. At a later point the priest’s touching became increasingly explicit. He would run his finger between Mr. Garcia’s buttocks.
When Mr. Garcia had to go to the storage supply closet to collect or return cleaning supplies, the priest would follow him and in the confined space of the closet run his hands over Mr. Garcia’s body. At other times, he would pull Mr. Garcia to him as if to hug him, but push Mr. Garcia’s face into his crotch in the course of doing so. He would also follow Mr. Garcia into the bathroom and expose himself. At first, he would do so while urinating, but at a later point he would pull out his penis and tell Mr. Garcia that one day his penis would also be big. At a later point he showed Mr. Garcia photographs of penises. . .
After exposing his penis to Mr. Garcia several times, the priest began telling him to touch it, telling him that he would not get into trouble for doing so. When Mr. Garcia began disclosing this phase of the abuse his voice became much more halting. At various points he had to stop speaking, and it was evident that he was experiencing both intense shame and anguish.
Eventually, Mr. Garcia disclosed that the abuse escalated to the priest rubbing his penis all over Mr. Garcia’s face. When I asked Mr. Garcia if the priest had penetrated his mouth with his penis, Mr. Garcia said that he could not remember. However, he did remember feeling wetness all over his face.
The priest’s sexual abuse of Mr. Garcia culminated in a violent, anal rape. Mr. Garcia could not remember where it occurred. His memories are fragments: feeling the priest’s penis rubbing against his back and his buttocks; feeling the priest pushing his penis into his rectum; feeling intense pain in his rectum. Mr. Garcia also remembered feeling searing pain in his rectum for days following the rape, especially when he defecated.
Declaration of Dr. David Lisak, Ph.D.
Dr. Lisak explains that these repeated sexual assaults caused unimaginable emotional and psychological pain and enduring trauma:
Mr. Garcia’s disclosure was anguished, and at several points during his description of the sexual abuse he experienced physical sensations that were very likely body memories associated with being raped by the priest. He also experienced intense humiliation and shame, emotional states that at times were so intense that he could not continue speaking.
. . .
The effects on Mr. Garcia of being abused and raped by his parish priest were profound and lifelong. He has been plagued his entire life by chronic nightmares. In the nightmares, he is often surrounded by men and knows that something terrible is about to happen. Then he sees a penis in front of his face and in that instant he wakes up covered in sweat and feeling intense pain in his rectum.
Mr. Garcia has harbored a profound distrust of people his entire life, a distrust that stems directly from the unimaginable betrayal of being raped by a priest, a man viewed by the 11 year old Mr. Garcia as an emissary of God. Distrust in people is a very common legacy among sexual abuse victims. Children are taught to respect adults, to seek help from adults, to expect protection from adults. When an adult then violates those expectations and that trust, the result is almost inevitably a profound distrust in people. This effect is enormously magnified when the adult who rapes the child possesses the almost infinite power of a priest. The priest represents the world of adults, the Catholic Church, and God. To the child raped by a priest, the rupture of trust and faith is very often irreparable.
Declaration of Dr. David Lisak, Ph.D.
Humberto was not the only victim of Father Fernandez’s predations. Fernandez was charged with indecency with a child in 1988 after two neighborhood boys accused him of having fondled them. Other victims have recently disclosed that they, too, had been sexually abused by Father Fernandez. Sister Maria, the nun who taught Humberto’s communion classes, told other sisters in her order that the priest was “an evil man.” She requested a transfer from St. Clare, and later withdrew from the church entirely. According to Dr. Lisak, Mr. Leal’s account is credible and consistent, and the effects of the sexual abuse were devastating:
It is my professional opinion, based upon my interview with Mr. Garcia, my review of relevant materials, and my evaluation of Mr. Garcia’s disclosure that he was sexually abused by his parish priest by the age of 11 or younger. Mr. Garcia’s description of the priest’s behavior, his description of his own symptoms and of the impact of the rape over time are all entirely consistent, and they leave no doubt that Mr. Garcia has made a credible disclosure.
Childhood sexual abuse is devastating to the developing child. To a child like Mr. Garcia, who is growing up in a home filled with violence and abuse, it is often catastrophic. And in Mr. Garcia’s case, the fact that he was abused and then raped by a Catholic priest, a man who represented the authority of the Church and was viewed as an emissary of God, profoundly magnified this trauma. The abuse and rape left Mr. Garcia with lifelong scars. It ruptured his capacity to trust people, and cast him into a permanent state of confusion and doubt about his essential worth as a person and as a man.
Declaration of Dr. David Lisak, Ph.D.
Mr. Leal also suffers from brain damage, the effects of which were exacerbated by the trauma of his sexual abuse and family violence. According to Dr. Ricardo Weinstein, a clinical psychologist retained by the government of Mexico, neuropsychological tests indicate that Humberto has significant damage to the frontal lobes of his brain, which direct the brain’s executive functions. Dr. Weinstein’s report attests that Humberto’s frontal lobe dysfunction had pronounced effects on his behavior. Frontal lobe dysfunction inhibited his ability to make decisions, foresee the consequences of his actions, assess risk, and adjust to different social environments. Dr. Weinstein also expressed concern about Humberto’s youth when he was convicted (he was only 21 years old at the time of his arrest). He notes that the frontal lobes are the last part of the brain to develop and are not fully mature in males until they reach their early 20s, and that this lack of complete brain maturation has significant implications for young adults’ decision-making abilities.
While Humberto faced great challenges in his personal life as a result of a troubled home life, developmental disabilities, and neurological damage, he was never involved with drugs or gangs like many other youths from his neighborhood. Neighbors remember Humberto as the most responsible of his siblings. He began working in his father’s garage at age thirteen, and would typically go straight to work after school. Family and friends recall Humberto as something of a loner, but talkative and eager to help others when he could, helping his younger sister Angela with her homework and assisting other students in his vocational classes in high school.
Several high school teachers remember him as being generally well behaved and friends remember he was popular with his teachers. Humberto formed personal relationships with his guidance counselor, Joann Danklef, and his 9th grade geography teacher Sharon Trujillo, taking an interest in their families and continuing to stay in touch for years after high school. When he was unable to pass the Texas Assessment of Academic Skills tests required to graduate, Ms. Danklef helped Humberto sign himself into special education when he turned eighteen and could finally enroll in special education without the consent of his parents. On his own initiative, and because of the positive relationships he built with his teachers, Humberto became the first member of his family to hold a high school diploma. Graduating from high school was one of the proudest moments of Humberto’s life.
It should be abundantly clear that Humberto does not deserve the death penalty. He had no prior criminal record. His prison record reveals that in the fifteen years that Humberto has now been on death row, he has not committed a single violent infraction. The testimony presented at trial that Humberto was a dangerous, antisocial person incapable of reform is clearly erroneous. Had he been given the opportunity to contact the consulate of Mexico to aid in his defense, he would have been vigorously defended by experienced lawyers retained by the consulate to assist him. Competent counsel would have exposed the weaknesses of the state’s evidence at the culpability phase, and would have presented powerful, humanizing evidence at the penalty phase. At a minimum, Humberto Leal never would have been sentenced to death – and there is a reasonable likelihood that he would not have been convicted of capital murder.
1. According to a prosecution witness, one of the rapists was heard encouraging others to insert an object into the victim’s vagina – a fact that is relevant to the evidence found at the crime scene. [Back]
2. Tr. 15:454-55, 459-460, 490. [Back]
3. Tr. 16:793. [Back]
4. Tr. 13:106. [Back]
5. Id. at 106. [Back]
6. Tr. 16:771-73 (“Again, my concern [is that] you stated the evidence that raises the issue of kidnapping is the confession of the defendant. Which, under the case law, is not sufficient in and of itself.”). [Back]
7. Tr. 13:42-44; 47; 62; 121. [Back]
8. Tr. 16:665-66. [Back]
9. Leal v. State, 303 S.W.3d 292 (Tex. Crim. App. 2009) (citing testimony of Roche serologist Megan Clement). [Back]
10. Tr. 16:829. [Back]
11. Kristopher L. Artheart and Iain A. Pretty, Results of the 4th ABFO Bitemark Workshop – 1999, Forensic Science International, Volume 124, 2001. A 1975 study, conducted on animal skin, resulted in an error rate of 84% after twenty-four hours. David A. Whittaker, Some Laboratory Studies on the Accuracy of Bite Mark Comparison, 25 Int’l Dental J. 166 (1975). [Back]
12. National Academy of Sciences, Strengthening Forensic Science in the United States: A Path Forward (February, 2009), pages 173-176, available at http://books.nap.edu/openbook.php?record_id=12589&page=173. [Back]
13. Id. [Back]
14. Id. [Back]
15. Id. [Back]
16. OAS Report No 90-09 at 29 ¶ 145. [Back]
17. Tr. 17 at 8. [Back]
18. Interview with Richard Calhoun. [Back]
19. Id. [Back]
DDHH en México
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