After 27 years on Louisiana's death row, Jimmie "Chris" Duncan now has the state's highest court saying he never should have been there in the first place. On Monday, the Louisiana Supreme Court affirmed a lower court ruling that Duncan should not have been convicted in the 1993 death of a toddler, concluding that the new record shows "no rational juror" would vote to convict him.
Duncan's death sentence was thrown out last year and he was released on bond while courts weighed the state's appeal. The new ruling closes one chapter in a long and bitter fight over forensic evidence, and it could help reshape how Louisiana courts handle post-conviction claims built on new scientific analysis.
In a 33-page opinion written by Justice Cade R. Cole, the court upheld an Ouachita Parish judge's 2025 order vacating Duncan's conviction. The justices agreed that Duncan met the legal burden of showing, by clear and convincing evidence, that a juror today could not find him guilty beyond a reasonable doubt. NOLA reported that Chief Justice John Weimer filed a concurrence that likened the bite-mark technique at the center of the case to a kind of "trial by water," a pointed comparison to long-discredited methods of determining guilt.
The original conviction leaned heavily on bite-mark identification testimony from pathologist Dr. Steven Hayne and forensic dentist Dr. Michael West, a technique that has since been widely rejected by mainstream forensic scientists. Investigations by ProPublica and Verite News, along with later court testimony, surfaced video and expert analysis that called into question the reliability of the marks prosecutors used to link Duncan to the crime. The Death Penalty Information Center has noted that several other convictions have also unraveled after similar bite-mark testimony from Hayne and West came under scrutiny.
Judge Alvin Sharp threw out Duncan's conviction in April 2025, declaring the bite-mark evidence "no longer valid" and pointing to other evidence that fit an accidental drowning theory. Duncan walked out of prison on bond in November 2025 while the state appealed. The Associated Press reported on the bail order and Sharp's explanation at the time, which leaned heavily on new expert testimony and fresh doubt about the original autopsy and investigative record.
Ouachita Parish District Attorney Robert Tew has repeatedly said his office will keep fighting to preserve the conviction and has hinted they may attempt to retry the case if the law allows it. Local court coverage captured Tew saying the state intends to keep pressing the case. KATC detailed the arguments offered by both sides at oral argument and noted the presence of toddler Haley Oliveaux's family in the courtroom.
Post-Conviction Law And What Comes Next
Under Louisiana's post-conviction statute, expanded in 2021 as Code of Criminal Procedure Article 926.2, an incarcerated person seeking relief has to bring in new, reliable evidence and then prove, by clear and convincing evidence, that "no rational juror" would have convicted them. The law ties relief directly to that standard and still allows the state to retry the underlying charges even after a conviction is vacated, so prosecutors are not locked out of a second shot at trial. The Louisiana Legislature also sets the criteria for compensation and other remedies when courts ultimately determine that someone is factually innocent.
For defense lawyers and innocence advocates, the Duncan ruling is likely to be read as a strong vote of confidence in this 2021 pathway for people whose convictions leaned on outdated or debunked forensic methods. Prosecutors and some relatives of victims counter that having a conviction vacated under the statute is not the same thing as an acquittal, and they emphasize that the state still has tools, including retrial or further appeal. That tension was on full display at oral argument, as reported by local outlets, and continues to hang over the case. ProPublica has tracked how new testing and expert work have shifted the landscape in several high-profile Louisiana cases tied to similar forensic testimony.
Relatives of Haley Oliveaux have attended hearings in the case and have said publicly that they remain convinced Duncan is guilty. By contrast, lawyers and experts who worked on Duncan's post-conviction petition have described the ruling as a long overdue correction of a faulty forensic story. Local coverage has captured the raw emotion in the courtroom, with family members watching closely as the legal fight edges into a new phase. KATC and other outlets have reported both the family's reactions and sharply different statements from the defense team.
The Supreme Court's decision is likely to ripple beyond Duncan's case. Other Louisiana convictions have also relied on work by Hayne and West, and advocates say this ruling could become a landmark example of how courts apply the new post-conviction standard when forensic science moves on. The Death Penalty Information Center has cataloged multiple convictions tied in part to the pair's testimony, framing the Duncan case as part of a broader national reassessment of forensic practices in capital cases. For Duncan, the legal process is not over, but after nearly three decades on death row, the ground under his conviction has shifted in a very public way.
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