Willie Roy Jenkins v. Texas

The State’s theory of capital murder in this case was Mr. Jenkins committed murder in the course of committing a sexual assault. The case was deemed solved, some four decades after the murder, by DNA evidence allegedly connecting him to spermatozoa inside the victim and the blouse she was wearing when she died. The State’s witnesses told the jury that the pathologist who conducted the autopsy had passed away and was therefore unable to testify, but that he had concluded a sexual assault occurred. This was untrue. The pathologist was actually alive at the time of trial, and willing to testify that he found no injuries consistent with sexual assault and that the spermatozoa he found was consistent with a sexual encounter prior to her death—information that was in a police report in the State’s possession. Mr. Jenkins filed an initial habeas corpus application raising that the State introduced multiple instances of false testimony at his trial. While Mr. Jenkins’s initial state habeas proceedings were pending, the crime lab reinterpreted the DNA evidence and concluded that they could no longer connect Mr. Jenkins to the blouse, which the State originally argued was a “date and timestamp” that proved Mr. Jenkins had committed the murder and sexual assault. Mr. Jenkins filed a subsequent habeas corpus application, raising that the new evidence rendered DNA analyst testimony at his trial false and that he is actually innocent. The Texas Court of Criminal Appeals denied Mr. Jenkins’s initial application by applying a never-before-used procedural bar to the false evidence claims, holding Mr. Jenkins’s trial counsel should have discovered the falsities, corrected them, and preserved them for direct appeal. In the same order the TCCA dismissed Mr. Jenkins’s subsequent application without explanation. In Glossip v. Oklahoma, this Court held that a Napue false evidence claim imposes ‘the responsibility and duty to correct’ false testimony on ‘representatives of the State,’ not on defense counsel.” 604 U.S. ----, 145 S.Ct. 612, 630 (2025). In light of the preceding facts, this case presents the following questions:

1. Was the novel state procedural ground for denying the false evidence claims in the initial habeas application inadequate?

2. Was the state procedural ground dismissing the subsequent application independent of federal law when it required an applicant to make a prima facie case for relief on the underlying federal claim?

3. Whether Mr. Jenkins’s Fourteenth Amendment rights were violated due to the cumulative presentation of false evidence at his capital trial?