About | HeinOnline Law Journal Library | HeinOnline Law Journal Library | HeinOnline
LOG IN
LOG IN

41 Am. Crim. L. Rev. 157 (2004)
When Money Isn't Enough: The Case for Holistic Compensation of the Wrongfully Convicted

handle is hein.journals/amcrimlr41 and id is 167 raw text is: NOTES WHEN MONEY ISN'T ENOUGH: THE CASE FOR HOLISTIC COMPENSATION OF THE WRONGFULLY CONVICTED Shawn Armbrust* I. INTRODUCTION Ray Milton Krone graduated in the top ten percent of his high school class and went on to became a sergeant in the United States Air Force.' After an honorable discharge, he took a job in Arizona with the United States Postal Service, living a normal, middle-class life.2 But, in 1991, his life changed. A witness to the murder of bartender Kim Ancona told police that someone named Ray was supposed to help Ancona close the bar.3 Krone had socialized with Ancona in the past and was considered a regular customer at the bar.4 He immediately became a suspect. At trial, Krone was convicted primarily on this testimony, in addition to that of a bite-mark expert who testified that Krone's bite matched the bite-mark found on the victim.5 The court sentenced him to death for Ancona's murder.6 The Arizona Supreme Court reversed this conviction in 1995 because the prosecution had waited until one day before trial to turn over a crucial video made by their bite-mark expert.7 Krone was again convicted, however, despite present- ing ten DNA and bite-mark experts who testified that he could not have committed the crime.8 But in 2000, his attorney persuaded a judge to compare DNA samples from the victim's body with those in a database of people convicted of serious crimes.9 The DNA found on Ancona matched that of a convicted - and already * B.S., Northwestern University, 1999; J.D., Georgetown University Law Center, 2004. The author would like to thank Anne Geraghty, Chris Boran, Kirk Bloodsworth, Richard Dieter, Rob Warden, and Tim Sparapani for their help and support. 1. Ray Krone, Our Death Penalty System is Broken, and I Should Know, THE RECORD, May 9, 2002, at 107. 2. Id. 3. State v. Krone, 897 P.2d 621, 622 (Ariz. 1995) (describing the evidence that initially caused police to suspect Krone). 4. Id. 5. Id. at 622 (Without the bite-marks, the State arguably had no case.). 6. Id. at 623. 7. Id. at 622-25. The video presented a detailed description of how the expert was able to match Krone's bite-marks to those of the perpetrator. 8. Thomas Fields-Meyer et al., Free at Last, PEOPLE, Dec. 2, 2002, at 62, 66 (describing the crime of which Krone was convicted and the chronology of the case). 9. Richard Willing, Exonerated Prisoners are Rarely Paid for Lost Time, USA TODAY, June 18, 2002, at IA.

What Is HeinOnline?

HeinOnline is a subscription-based resource containing thousands of academic and legal journals from inception; complete coverage of government documents such as U.S. Statutes at Large, U.S. Code, Federal Register, Code of Federal Regulations, U.S. Reports, and much more. Documents are image-based, fully searchable PDFs with the authority of print combined with the accessibility of a user-friendly and powerful database. For more information, request a quote or trial for your organization below.



Short-term subscription options include 24 hours, 48 hours, or 1 week to HeinOnline.

Purchase Access

Contact us for annual subscription options:

Contact Us

Already a HeinOnline Subscriber?

Log In

profiles profiles most