Amicus Brief: Jennifer Baldwin
CLARENCE Jones III v. the State of maryland
Filing Date
June 10, 2025
Charge
Unintentional Second-Degree Murder
Jurisdiction
State of Minnesota in Court of Appeals
Partners
Innocence Network
Summary
CIFS participated in this amicus brief filed by the Innocence Network in the Supreme Court of the State of Montana in Katherine Proctor’s case. They outline Montana Rule of Evidence 702, requiring that scientific evidence offered by expert opinion must be reliable. The state expert in Proctor’s case concluded that small subdural hemorrhage, hemorrhaging in the eyes, and hypoxic-ischemic injury are evidence that the baby was shaken. They argue the conclusion is not based on a reliable scientific method of study, therefore, violating rule 702.
PRELIMINARY STATEMENT
In Appellant Jennifer Lynn Baldwin’s case, the State relied on two unreliable forensic disciplines to convict her. First, a diagnosis of death by Shaken Baby Syndrome (“SBS”; sometimes called Shaken Baby Syndrome/Abusive Head Trauma, or “SBS/AHT”), which is a medical theory that has produced vast disagreement in the medical community. These cases depend heavily on expert testimony that is “often . . . determinative” of guilt or innocence. Keith A. Findley et al., Feigned Consensus: Usurping the Law in Shaken Baby Syndrome/Abusive Head Trauma Prosecutions, Wis. L. Rev. 1211, 1247 (2019) (“Findley I”). Second, analysis of Ms. Baldwin’s 911-call based on the erroneous assumption that trained examiners can differentiate indicators of innocence from indicators of guilt by merely listening to the call.
In this appeal, Ms. Baldwin challenges the district court holding that her postconviction medical evidence SBS/AHT claim and 911-call analysis claim are procedurally barred under State v. Knaffla, 243 N.W.2d 737 (Minn. 1976). Underlying these issues is the tension between science and law, and the question of when a postconviction petitioner should be considered to have known about a shift in forensic science evidence. The Court’s decision on this question will clarify standards for how postconviction courts consider the role shifting science plays in jury trials and how and when its findings based on such science should be disturbed on appeal. This matter raises compelling issues for which the Network has particular interest, and it respectfully submits this brief as amicus curiae in support of Ms. Baldwin. The Network urges this Court to reverse the decision of the district court.