US v. Seward: In 2019 a US Postal Service employee was found dead, shot multiple times, along the side of a South Carolina road. Two miles down the road investigators found a rifle, 21 bullet casings, and a package containing two pounds of marijuana addressed to Seward that had the mail carrier’s blood on it. Investigation led to Seward being charged with the carrier’s murder, along with related charges, for which the jury found him guilty on all counts.
The Fourth Circuit affirmed Seward’s convictions, rejecting three arguments on appeal. First, it concluded that the district court did not abuse its discretion in allowing the Government’s toolmark expert to testify. Noting that it had already rejected a head-on challenge to the “science” of toolmark matching, the court also held that issues with the expert’s qualifications were adequately addressed via cross examination. Second, the court held there was no error in excluding evidence that an alternate suspect failed a polygraph test, noting the general inadmissibility of such results and that Seward was able to address the issue of that subject’s inconsistencies with the postal inspector who led the investigation. Finally, the court held that the Government’s DNA expert’s testimony may have violated Seward’s confrontation clause rights (it could not reach a conclusion on that issue due to lack of development in the district court), but that any error was harmless in light of “overwhelming evidence of Seward’s guilt.”
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