Sean Patrick Goble v. State of Tennessee

Citation: Not availableDocket: E2018-01659-CCA-R3-PC

Court: Court of Criminal Appeals of Tennessee; September 13, 2019; Tennessee; State Appellate Court

Original Court Document: View Document

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Sean Patrick Goble appeals the summary dismissal of his petition under the Post-Conviction DNA Analysis Act of 2001 by the Greene County Criminal Court, which denied relief based on the conclusion that DNA results would not exculpate him from his first-degree murder conviction. Goble, who received a life sentence for the 1995 murder, had previously sought post-conviction relief in 1997, which was dismissed as untimely. In 2015, he filed a petition for DNA analysis, claiming his DNA had not been compared with evidence from the victim. Initially, the State did not respond, leading to a summary dismissal on timeliness grounds. However, upon appeal, the court ruled that the one-year statute of limitations did not apply to DNA petitions, remanding the case for further consideration. 

In 2018, the State submitted a laboratory report indicating DNA from the victim and an unknown individual, acknowledging that Goble’s DNA had not been compared with that of the unknown person. The State also submitted Goble's written confession, which included details about the murder and his initial falsehood regarding sexual intercourse with the victim. The State argued that the evidence did not demonstrate a likelihood of a different trial outcome or that prosecution would not have occurred. The appellate court affirmed the post-conviction court's judgment.

The State contended that DNA analysis showing a mismatch with the Petitioner does not exonerate him, as the victim's sexual activity with others does not negate his admission of murder. On August 13, 2018, the post-conviction court denied the Petitioner’s request for relief, emphasizing that he had provided a comprehensive confession detailing the circumstances of the murder, including the location and method, and had drawn a diagram of the crime scene. The court noted inconsistencies in the Petitioner’s statements regarding sexual intercourse with the victim, but found them irrelevant since he had confessed to the murder. The court established that the case details included the Petitioner meeting the victim at a truck stop and subsequently killing her. It ruled that the DNA evidence did not create a reasonable probability of the Petitioner’s non-prosecution or conviction and characterized his request for DNA analysis as an attempt to obstruct justice rather than to prove innocence.

Under T.C.A. 40-30-303 (2018), convicted persons can petition for forensic DNA analysis of evidence related to their case, provided it may contain biological evidence. Mandatory testing is required if specific criteria are met, including a reasonable probability that the Petitioner would not have been prosecuted if the DNA analysis yielded exculpatory results, the evidence's existence and condition allow for testing, the evidence has not been previously analyzed, and the request is genuinely aimed at proving innocence. A post-conviction court can dismiss a petition without a hearing if the Petitioner fails to meet all criteria outlined in Code section 40-30-304. The court's decision is upheld unless it lacks substantial evidence, as supported by precedents.

The Petitioner claims the post-conviction court incorrectly dismissed his request for DNA analysis, arguing that his request met the criteria established in Code section 40-30-304. The State contends the court's denial was appropriate because the Petitioner did not fulfill the necessary criteria. In 1995, the Petitioner confessed to murdering the victim, detailing their encounter at a truck stop, his agreement to drive her to Virginia, and the subsequent strangulation and disposal of her body. He provided a map indicating where he left her remains and later admitted to having sexual intercourse with the victim prior to her death. The court concluded that allowing DNA testing would not alter the outcome, as the Petitioner’s own statements already established his culpability. The presence of his DNA would simply corroborate his confession, while DNA from another individual would not exonerate him. The court found that he did not demonstrate how DNA analysis would prevent prosecution or conviction, thus denying his request. Additionally, the Petitioner’s claim regarding the suppression of his confession due to a violation of his right to counsel was deemed not cognizable under the applicable Act. Consequently, the post-conviction court's judgment is affirmed.