Louisiana Supreme Court frees Jimmie “Chris” Duncan after “scientifically indefensible” forensics

Jimmie “Chris” Duncan is officially a free man after the Louisiana Supreme Court unanimously upheld the overturning of his 1998 death sentence. In the opinion, Justice Cade R. Cole wrote that new post-conviction evidence left “no doubt” the conviction should come off the books, and he pointed squarely at the forensics used to convict him.

Cole said the post-conviction evidence undermined “the core factual premises on which the state depended.” And when the court reexamined the bite-mark theory that tied Duncan to Haley Oliveaux’s death, it concluded it was “scientifically indefensible” to identify the marks as having been made by Duncan. The decision also referenced a 1993 video of forensic dentist Michael West taking a mold of Duncan’s teeth and grinding it across Haley’s body, creating bite marks that, according to the court, did not exist before, and showing angles Cole wrote were physically impossible for a human bite.

This is the kind of ruling that makes court-watchers sit up, and it is not just because it freed a man who had faced execution. The Supreme Court’s language lands in the middle of a broader, ongoing reckoning over forensic science reliability, especially in capital cases where mistakes cannot be rolled back. The case came after a 2025 Verite News and ProPublica investigation examined the reliability of the key forensic evidence used to convict Duncan, now 57. The stakes were unusually high at the time: Duncan faced the possibility of being put to death as Gov. Jeff Landry, a staunch death penalty advocate, made moves to expedite executions after a 15-year pause.

Duncan’s conviction rested largely on bite mark evidence presented at trial by West and pathologist Steven Hayne. Their analysis, which Ouachita Parish prosecutors relied on to secure a murder conviction, claimed to match marks on Haley’s body to Duncan’s teeth. But the court’s opinion now reflects what many experts have said about bite-mark evidence since the 1990s: evidence that was “fairly common at the time” is now widely viewed as junk science. Civil rights attorneys, forensic experts, and courts have scrutinized the longtime partnership between West and Hayne over concerns about the validity of their techniques.

The ripple effects are not theoretical. In the 28 years since Duncan’s trial, nine other prisoners have been set free after being convicted in part on inaccurate evidence from West and Hayne, including three men on death row. Duncan was the last person awaiting an execution based on the pair’s work. That detail matters because it frames this not as an isolated error corrected by a single court, but as a systemic exposure: one technique and one evidentiary pipeline, used repeatedly enough to reach death row.

The opinion also includes a concurrence from Chief Justice John Weimer, who compared the bite-mark process used in Duncan’s prosecution to “trial by water” tests used by witch-hunters in the 17th century. In that historical ritual, suspected witches were bound and lowered into water; floaters were deemed guilty of witchcraft and sinkers often died. Weimer wrote that modern observers look back on those practices as “asinine and absurd” because many victims did not survive regardless of guilt. He argued the bite-mark evidence and the sexual abuse evidence used at trial were “similarly specious,” and he emphasized the irreversibility of death penalty mistakes: a final sentence carried out on evidence “devoid of legitimacy” is “inimical and deleterious” to the system of justice.

The case narrative itself is chilling. Police arrested Duncan on Dec. 18, 1993. He was babysitting Haley Oliveaux that day in a home he shared with the girl’s mother in West Monroe. Duncan told law enforcement he had put the child in the bath, then went downstairs to wash dishes. When he heard a noise coming from the bathroom, he rushed upstairs and found Haley floating face down in the water. She was pronounced dead a few hours later. Prosecutors originally charged Duncan with negligent homicide, then upped the charge to first-degree murder after Hayne and West conducted Haley’s medical exam and claimed to discover evidence, including purported bite marks, that she had been sexually assaulted and intentionally drowned. After two weeks of testimony in 1998, the jury convicted Duncan and sentenced him to death.

Duncan’s post-conviction case later turned on evidence pointing away from homicide. His new team of attorneys uncovered an expert witness who said the child’s death was not a homicide but the result of an accidental drowning. Investigators working with Duncan’s legal team also interviewed a jailhouse informant who recanted earlier trial testimony that Duncan had confessed. His conviction was overturned in April of last year by former Ouachita Parish Judge Alvin Sharp. He was released from prison on bail in December, but remained in limbo after prosecutors appealed.

Even with the Supreme Court’s ruling on Monday, the conflict over procedure and future liability did not vanish. Steve Tew, district attorney for Ouachita and Morehouse parishes, has insisted Duncan was guilty and argued he should be put to death. His office appealed Sharp’s overturning decision, and during oral arguments in April, Tew argued that because Duncan was the only person with Haley at the time of her death, guilt was not debatable. Tew also said, at the hearing, that if the state Supreme Court refused to reinstate Duncan’s conviction, he would retry him, though he did not specify what charge he might pursue. The Innocence Project attorney Chris Fabricant, director of strategic litigation with the Innocence Project in New York, said, “If there is any sense of fairness and justice left, this should be the end of this case.”

For executives and board members, the strategic takeaway is surprisingly transferable: when high-stakes decisions are built on scientific-sounding evidence, reliability becomes a corporate governance issue, not just a legal one. If courts repeatedly have to correct the same evidentiary failure modes, systems around review, incentives, and validation fail in the same places. Duncan’s case is a stark example, and its consequences reach beyond criminal justice. It is a signal to anyone making irreversible calls that “common at the time” is not a defense, and that scrutiny over methodology is not optional when the outcome is permanent.