Jimmie 'Chris' Duncan, who spent 27 years on death row, has had his murder conviction overturned by the Louisiana Supreme Court. The ruling came after the emergence of a video showing forensic dentist Michael West creating evidence by pressing a mold of Duncan's teeth into the victim's skin.
Duncan was convicted in 1998 of the 1993 murder of Haley Oliveaux, his girlfriend's toddler, who drowned in a bathtub while Duncan was babysitting. The prosecution's case relied heavily on bite mark evidence presented by West and forensic pathologist Steven Hayne. The newly revealed footage shows West repeatedly pressing and scraping a mold of Duncan's teeth against the child's body, including her cheek, arm, and elbow, under a blue light. Experts now contend that West's actions created the marks that were later presented as evidence of bite marks, implicating Duncan in rape and murder.
At the time of the original trial, the defense requested access to the video, but the judge ruled it contained no exculpatory evidence. The jury was unaware of the footage and deliberated for less than three hours before convicting Duncan and sentencing him to death.
Questioning Forensic Science
The case of Duncan is one of at least 10 instances, including four death row prisoners, where convictions have been linked to the discredited work of Hayne and West, who partnered on thousands of autopsies across Louisiana and Mississippi. Their work often aligned with conclusions desired by law enforcement.
In 1993, after Oliveaux's drowning, initial medical examinations did not note any bite marks. Bruising was observed, but no evidence of sexual assault was found. Duncan was initially charged with negligent homicide. However, after his daughter's body was transported to Mississippi for an autopsy by Hayne, he claimed to have seen bite marks, prompting West's examination. West's report concluded a "positive match" to Duncan's teeth.
During Duncan's 1998 trial, prosecutors did not call West to testify, as his credibility was already under scrutiny. He had faced a one-year suspension for overstating his credentials and misidentifying bite marks, and another Louisiana murder conviction had already been overturned due to concerns about his reliability. Prosecutors presented testimony from another forensic dentist who based conclusions on photographs of the marks, without viewing West's video.
By 2009, the scientific community began to question the validity of bite mark analysis. A National Academy of Sciences report stated there was no evidence that bite marks could be definitively linked to a specific suspect. In 2012, West himself disavowed bite mark analysis in a deposition, stating, "I no longer believe in bite mark analysis... I don't think it should be used in court."
Path to Exoneration
In 2022, the Innocence Project joined Duncan's legal team, focusing on the video in a new appeal under a state law allowing defendants to argue for "factual innocence" by presenting evidence that should have been introduced at trial. The defense argued the video showed West tampering with evidence.
Retired district court judge Alvin Sharp, who reviewed the case, described the footage as "aghast" and stated West was "absolutely creating marks on that baby's body." In April 2025, Sharp granted Duncan's claim of factual innocence and vacated his conviction, citing improper scientific evidence from Hayne and West.
Prosecutors appealed the decision, but the Louisiana Supreme Court upheld Sharp's ruling last month. The court found that Duncan had proven by "clear and convincing evidence that no rational juror would have found him guilty beyond a reasonable doubt of first-degree murder had the new evidence been presented at trial." Chief Justice John L. Weimer compared bite mark analysis to archaic methods like "trial by water" used against accused witches.
Despite the overturned conviction, the current district attorney for Ouachita Parish, Steve Tew, has stated he still believes Duncan is guilty and intends to prosecute him again. The original prosecutor, Jerry Jones, also maintains Duncan's guilt but expressed regret for using the bite mark testimony, admitting, "That bite mark evidence was bad and I shouldn't have introduced it, but I didn't know that at the time."
Duncan was released on bail last November while the Supreme Court heard his case. He had spent 27 years on death row fighting the accusation.
