Wally Kay Schultz contended in his appeal that if the misconduct had been known and his case had gone to trial, a jury would likely have considered the lab scientist to be less than credible, and that would have resulted in a "not guilty" verdict.
But in a ruling handed down earlier this week, the unanimous appellate court panel rejected Schultz's argument, saying he failed to show the misconduct at the lab affected the accuracy of the drug test results in his case.
Schultz was sentenced to five years in prison after he pleaded guilty in 2007 to possession of methamphetamine in Minidoka County. But in 2011, he received a letter indicating that the Idaho State Police had just discovered misconduct occurred at the forensic laboratory that tested the drugs in Schultz's case. According to the court documents, between 2003 and 2011, the scientists at the lab kept a secret box of drugs that they used for training and display purposes. The box was intentionally kept hidden from auditors, according to the court documents.
The scientist who tested the drugs in Schultz's criminal case was involved in the misconduct and was listed as a witness for the prosecution before Schultz decided to plead guilty. Schultz said that if he'd known of the misconduct at the time, he could have gone to trial and challenged the credibility of the scientist before a jury.
The state countered that the alleged misconduct at the lab didn't involve forensic testing and that the Lab Accreditation Board of the American Society of Crime Laboratory Directors was satisfied with the steps taken by the Idaho State Police to resolve the issue.
The appellate court found that prosecutors aren't obligated to reveal all information that would make their witnesses seem less credible to a jury, only that they must share with the defendant any evidence that would suggest the defendant isn't guilty of the crime. Besides, the appellate court found, there was no nexus between the misconduct and the methamphetamine testing done in Schultz's case.
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