📄 Motion: hair sample limitation — Thursday, June 30, 1994
Address:
C:\DEPT103\PRELIMINARY\1994\JUN\30\MOTION-HAIR-SAMPLE-LIMITATION.DOC
TRIAL
▲ Day 1 of 6

Motion: hair sample limitation

Date: Thursday, June 30, 1994 • Utterances: 28
The court addressed a defense motion to limit the hair sample taken from OJ Simpson to a single hair. Clark argued that forensic standards require five to ten hairs per area of the scalp — roughly 100 total — for effective microscopic comparison, while Shapiro cited Dr. Henry Lee's opinion that one to three hairs suffice. The judge split the difference, ordering no more than ten hairs for now, with the option for a full expert hearing if the prosecution needs more.
1 THE COURT:

Good morning. Now, there are a number of matters on calendar today. I think there is one matter that can be resolved in fairly short order, and that relates to the hair sample that the court did grant an order for a hair sample. The defense submitted an order to the court requesting to limit that hair sample to one hair. I did have my clerk contact the District Attorney's office to determine whether they were in agreement with that order, and the indication was that they were not, and therefore I've done nothing with regard to that order to this point. Ms. Clark, how much hair do the people need?

2 MS. CLARK:

Well, Your Honor, hair samples -- as I'm sure the defense must be aware -- in order to be effectively compared with an evidence sample recovered from a crime scene, has to be taken from each area of the suspect's head, and that means that a minimum of five to ten hairs from each area, which usually amounts to about a hundred hairs. Any scientist, no matter how inexperienced, is aware of that fact. You cannot do an effective comparison between a known standard and an evidence standard without that size of sample.

3 THE COURT:

So you're asking for 100 hairs?

4 MS. CLARK:

We're asking for as many hairs as the criminalist or expert determines is necessary to effectively compare the standard hairs from the head of the defendant with the hairs found at the crime scene. And I've never seen a court attempt to restrict that, because that is obviously a matter that a criminalist would have to determine based on what he can recover.

5 THE COURT:

Mr. Shapiro.

6 MR. SHAPIRO:

Your Honor, according to Dr. Henry Lee, our chief criminalist who is the head of the Department of Criminology in Connecticut, he tells us one to three hairs are sufficient. I think perhaps this may be an appropriate matter for the court to have a hearing on. I think 100 hairs is unduly invasive, makes the inventorying of the hairs a very, very difficult task, and certainly allows for the possibility of the comingling of samples, which could contaminate any test. So we would ask for a hearing on this. I've been practicing for a long time. I have never, ever heard of such a request.

KEY QUOTE
7 THE COURT:

All right. This is what I'm prepared to do at this point in time: that is to order, no more than 10 hairs at this point. If the prosecution at some point feels that they are in need of more hairs than the 10 that I'm going to allow at this point, then we will have that hearing with experts, if necessary. This is not a matter that the court has independent expert knowledge concerning, so that's going to be the order at this point in time, subject to a further hearing with evidence, if necessary, from both sides for anything beyond 10 hairs.

8 MS. CLARK:

Your Honor, I don't think that counsel has conferred with Mr. Lee concerning the nature of the tests involved. If Mr. Lee is -- and if Mr. Lee has informed counsel that only one to three hairs are needed for microscopic comparison, then he has misinformed counsel, and I can state that categorically. I'm very surprised to hear Mr. Shapiro has never heard of the number of hairs I have just indicated to the court being required before, because that is a standard thing. When a microscopic analysis is endeavored, it is required that you have standards from every area of the head, 10 hairs per area. That's a standard. I'm not talking about anything unusual here, and what Mr. Lee is talking about --

9 THE COURT:

Ms. Clark --

10 MS. CLARK:

-- Excuse me, is P.C.R. work. We're talking about comparison for microscopic as well. We're not just talking about P.C.R. only.

11 THE COURT:

At this point you're of the opinion, and it may indeed be the correct conclusion, that you're going to need more than that. The bottom line is that if, in fact, you do need more than that, you are going to have to produce an expert to justify that to the court. And if indeed that justification is made, I will sign the appropriate order.

12 MS. CLARK:

Thank you, Your Honor. We will present that testimony today.

13 THE COURT:

Today?

14 MS. CLARK:

Yes.

15 THE COURT:

Very well.

16 MS. CLARK:

Thank you very much.

17 THE COURT:

Okay. Now --

18 MR. SHAPIRO:

Your Honor, excuse me.

19 THE COURT:

Yes.

20 MR. SHAPIRO:

On the matter of hair, before you leave that issue, we do not have an indication as to how many follicles or shafts were found that the people are going to use for a point of comparison. May we ask the court to make such inquiry so we may have knowledge of that now?

21 THE COURT:

Yes. Ms. Clark, do you know the answer to that question at this point?

22 MS. CLARK:

I -- I was told just this morning, and I cannot recall -- I'm not going to make a representation. We have an expert here who can tell the court precisely how many follicles and how many shafts there are. I'd rather let them say.

23 THE COURT:

All right. Now, you indicate you do have an expert here. Do you want to proceed on this issue of the number of hairs right now, or would you prefer to do that some time later? What is your preference?

24 MS. CLARK:

Well, Your Honor, as I understand it, the court had required us to proceed this morning on the issue of the blood split that was requested.

25 THE COURT:

Yes.

26 MS. CLARK:

So the expert who is going to testify to that matter can also address matters of the hair because she's the director of the crime lab for the Los Angeles Police Department. So we can do it all at once.

27 THE COURT:

That would be fine. Mr. Shapiro, I assume that you are prepared on the hair issue?

28 MR. SHAPIRO:

Yes, I am, Your Honor, thank you.

Temperature

tense

Key Quotes (4)

Marcia Clark
a minimum of five to ten hairs from each area, which usually amounts to about a hundred hairs. Any scientist, no matter how inexperienced, is aware of that fact.
Clark frames Shapiro's position as scientifically illiterate, escalating a procedural dispute into a credibility clash over forensic expertise.
Robert Shapiro
according to Dr. Henry Lee, our chief criminalist who is the head of the Department of Criminology in Connecticut, he tells us one to three hairs are sufficient.
First on-record invocation of Dr. Henry Lee as a defense expert, previewing the defense's strategy of fielding world-class forensic witnesses against LAPD methods.
Marcia Clark
If Mr. Lee has informed counsel that only one to three hairs are needed for microscopic comparison, then he has misinformed counsel, and I can state that categorically.
Clark directly challenges Henry Lee's credibility before he has testified — a notable early skirmish over who controls the forensic narrative.
Kathleen Kennedy-Powell
if, in fact, you do need more than that, you are going to have to produce an expert to justify that to the court. And if indeed that justification is made, I will sign the appropriate order.
The judge's compromise ruling — ten hairs now, expert hearing for more — sets up an immediate evidentiary hearing the same morning.

Evidence (2)

Informal
Hair samples collected from OJ Simpson's scalp pursuant to court order
discussed — quantity disputed, court ordered ten hairs pending expert hearing
Informal
Hair follicles and shafts recovered from the crime scene (count unknown at time of hearing)
referenced — Shapiro requested disclosure of how many were found; Clark deferred to expert

Notable Exchanges (2)

Marcia ClarkRobert Shapiro
Clark and Shapiro offered directly contradictory forensic standards — 100 hairs vs. 1-3 hairs — with Clark interrupting her own argument to distinguish PCR analysis from microscopic comparison after Shapiro cited Lee.
heated
Marcia ClarkKathleen Kennedy-Powell
After the judge's ten-hair ruling, Clark immediately volunteered to present expert testimony that same morning, surprising the judge ('Today?') and folding the hair issue into the already-scheduled blood split hearing.
strategic

Credibility Attacks (1)

⚔ Dr. Henry Lee
expert opinion challenged
Clark stated categorically that Lee had 'misinformed counsel' if he advised that one to three hairs are sufficient for microscopic comparison, drawing a distinction between PCR work (where few hairs suffice) and the full microscopic standards the prosecution intended to apply.

Objections

None recorded
Proceeding 8947 • 28 utterances
Preliminary Trial
Department 103
⚖️ Start
📂 JUN 30, 1994 📄 Motion: hair sample limitation
JUN 30, 1994 KRT DvH TD