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Ricky Lee Pady v. the State of Texas

2026-08-20

Summary

Holding. The court affirmed the trial court's denial of Pady's motion for post-conviction DNA testing because Pady failed to demonstrate that the previously tested evidence could be subjected to newer testing techniques that would yield results more accurate and probative than the original tests.

Ricky Lee Pady, convicted in 2007 of murder, sought post-conviction DNA retesting of evidence from the crime scene and victim's vehicle. He argued the trial court should order retesting using newer techniques such as STR, mini-STR, Y-STR, and mitochondrial DNA testing, and that the DPS laboratory report was unclear about which DNA sample from Pady was used in the original comparison analysis. Pady also raised concerns that samples may have been confused with another suspect's DNA.

The court affirmed the trial court's denial. The statutory framework requires Pady to first show that evidence can be subjected to newer testing techniques that would provide results more accurate and probative than the original tests. At the hearing, Pady's own counsel conceded that the testing methods used in the original case appeared to be the same methods used today, specifically noting that the laboratory had already used STR testing. Because Pady failed to establish this threshold requirement, he could not invoke the statutory presumption favoring testing. The court also rejected Pady's claim that the lab report was unclear, finding the report identified separate DNA profiles from Pady, the victim, and the other suspect.

Summary generated by law.co from the public-domain opinion. The opinion text itself is public domain.

Key issues

  • Whether post-conviction DNA retesting is warranted when original testing used the same techniques available today
  • Whether the statutory presumption of exculpatory DNA results applies when the initial statutory threshold is not met
  • Whether ambiguity in a DNA laboratory report requires ordering retesting

Procedural posture

Pady appealed the 36th District Court of Aransas County's denial of his post-conviction DNA testing motion to the Thirteenth District Court of Appeals.

Authorities cited

Opinion

majority opinion

NUMBER 13-25-00444-CR

COURT OF APPEALS

THIRTEENTH DISTRICT OF TEXAS

CORPUS CHRISTI – EDINBURG

RICKY LEE PADY, Appellant,

v.

THE STATE OF TEXAS, Appellee.

ON APPEAL FROM THE 36TH DISTRICT COURT

OF ARANSAS COUNTY, TEXAS

MEMORANDUM OPINION

Before Justices Peña, West, and Fonseca

Memorandum Opinion by Justice West

Appellant Ricky Lee Pady challenges the trial court’s denial of his motion for postconviction DNA testing which sought retesting of previously tested evidence. See TEX.

CODE CRIM. PROC. ch. 64. Appellant argues the trial court erred because it did not “apply

the required statutory presumption that additional DNA testing” would show exculpatory

results. We affirm because appellant failed to show the evidence previously subjected to DNA testing “can be subjected to testing with newer testing techniques that provide a

reasonable likelihood of results that are more accurate and probative than the results of

the previous test.” See id. art. 64.01(b)(2)(A).

I. BACKGROUND

Appellant was convicted in 2007 of the murder of Denise Ortman, and he was

sentenced to fifty years’ incarceration. 1 On April 8, 2025, appellant filed a motion for postconviction DNA testing of certain DNA evidence recovered from Ortman’s vehicle and the

crime scene. 2 Specifically, appellant sought retesting of this evidence “using the most

probative and advanced means of testing, including STR or mini-STR testing, Y-STR

testing, as well as mitochondrial DNA testing.”

Attached to appellant’s motion were two laboratory submission forms and one

laboratory report from the Texas Department of Public Safety (DPS). The submission

forms listed evidence that the State submitted to DPS for DNA testing. One of the

submission forms listed appellant and “Rex Frautschi” as suspects and showed that the

State submitted an “oral swab” from Frautschi for testing.

The DPS lab report listed “all of the items and samples recovered by police” sent

for DNA testing in this case. It indicated the State submitted six batches of evidence for

testing, totaling fifty-two items or samples. Submissions I and II contained items or

samples from Ortman’s vehicle and the crime scene. Submission II also included blood

1 This Court affirmed Pady’s conviction. Pady v. State, No. 13-07-00075-CR, 2008 WL 5662120,

at *1 (Tex. App.—Corpus Christi–Edinburg Nov. 13, 2008, pet. ref’d) (mem. op., not designated for publication).

2 Appellant also requested “new testing on 2 cellular phones that were not entered into evidence

during his trial.” At the hearing on appellant’s motion, it was revealed there was only one cell, and the parties generally agreed there was likely no biological material on it. However, appellant does not challenge the trial court’s denial of his request to test the cell phone for DNA evidence. Accordingly, we do not address the cell phone in our background or analysis. See TEX. R. APP. P. 47.1.

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samples from appellant and Ortman. Submissions III, IV, V, and VI included an oral swab

from Frautschi and multiple DNA samples from Ortman. As to testing methods, the report

noted the DNA isolated from the submissions were “analyzed using a PCR based

method,” and “DNA STR (short tandem repeat) loci were characterized.”

As to the DNA results, the report indicated thirteen samples of apparent blood

stains from the crime scene matched only the DNA profile of Ortman. Partial DNA profiles

obtained from the handle of a knife found in the vehicle, an apparent blood stain on the

vehicle’s front bumper, and an “apparent bloodstain on the GPS faceplate of trash heap”

at the scene were also only consistent with Ortman’s DNA profile. A cigarette butt found

inside Ortman’s vehicle, and a shirt recovered from Frautschi’s residence only matched

the DNA profile of appellant. Lastly, two other cigarette butts found inside Ortman’s

vehicle only matched the DNA profile of Frautschi.

Appellant’s motion largely contended the DPS lab report “fail[ed] to show what

DNA sample of [appellant] was used by the DPS laboratory to make its ‘matches’ to

[appellant],” because, he alleged, the report “clearly made comparisons of items against”

Frautschi’s oral swab. He contended if a new sample of DNA was taken from appellant

today and “tested against all items previously tested” in Submissions I and II, “there might

be completely different results as we cannot know what DPS used as [appellant]’s sample

in its original testing.”

The trial court held a hearing on appellant’s motion. Appellant’s counsel conceded

that, from his research and review of the DPS records, the DNA testing methods used in

appellant’s case “appear[ed] to be the same sort of testing methods that they use today.”

Nevertheless, counsel requested the trial court order retesting of all the previously tested

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evidence “to see if newer testing can provide a result that would point to Rex Frautschi

as being a DNA contributor.” He argued if the evidence contained Frautschi’s DNA, then

that would be “exculpatory evidence that would favor the eventual moving for a new trial.”

The trial court denied the motion at the conclusion of the hearing, stating it did not

hear any evidence “of any great advancement in DNA testing in the last” two decades

“that would make these findings obsolete or questionable.” The trial court signed the order

denying appellant’s motion on August 13, 2025. This appeal ensued.

II. STANDARD OF REVIEW AND APPLICABLE LAW

We review the trial court’s denial of post-conviction DNA testing under a bifurcated

standard. Reed v. State, 541 S.W.3d 759, 768 (Tex. Crim. App. 2017). We afford almost

total deference to the trial court’s determination of issues of historical fact and application

of the law to fact issues turning on witness credibility and demeanor. Id.; Holberg v. State,

425 S.W.3d 282, 285 (Tex. Crim. App. 2014). However, we consider “all other applicationof-law-to-fact questions” de novo. Reed, 541 S.W.3d at 768–69.

Texas Code of Criminal Procedure Chapter 64 permits a convicted person to file

a post-conviction motion, in the court in which they were convicted, requesting items that

were previously tested for DNA be retested or DNA testing be performed on items that

were not tested at the time of trial. TEX. CODE CRIM. PROC. art. 64.01. As to retesting items

that were previously DNA-tested at the time of trial, the convicted person must show those

items (1) “can be subjected to testing with newer testing techniques that provide a

reasonable likelihood of results that are more accurate and probative than the results of

the previous test” or (2) the previously tested items were tested “at a laboratory that

ceased conducting DNA testing after an audit by the Texas Forensic Science Commission

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revealed the laboratory engaged in faulty testing practices” and were tested “during the

period identified in the audit as involving faulty testing practices.” Id. art. 64.01(b)(2). The

convicted person must attach an affidavit to his motion providing “statements of fact” in

support of the claims. Id. art. 64.01(a-1).

If these predicates are satisfied, the convicting court may order forensic DNA

testing only if the court also finds: (1) the evidence “still exists and is in a condition making

DNA testing possible”; (2) the evidence “has been subjected to a chain of custody

sufficient to establish that it has not been substituted, tampered with, replaced, or altered

in any material respect”; (3) “there is a reasonable likelihood that the evidence contains

biological material suitable for DNA testing”; and (4) “identity was or is an issue in the

case.” Id. art. 64.03(a)(1). The convicted person must then establish by a preponderance

of the evidence that (A) they “would not have been convicted if exculpatory results had

been obtained through DNA testing,” and (B) “the request for the proposed DNA testing

is not made to unreasonably delay the execution of sentence or administration of justice.”

Id. art. 64.03(a)(2). As to the former requirement, the trial court must assume without

deciding that the results of the post-conviction DNA testing would prove favorable to the

convicted person. See id. art. 64.03(a)(2)(A); Reed, 541 S.W.3d at 774; Routier v. State,

273 S.W.3d 241, 257 (Tex. Crim. App. 2008).

III. DISCUSSION

Appellant argues the trial court erred because it did not “apply the required

statutory presumption that additional DNA testing” would show exculpatory results. See

TEX. CODE CRIM. PROC. art. 64.03(a)(2)(A); Reed, 541 S.W.3d at 774; Routier, 273 S.W.3d

at 257. Appellant also contends the DPS lab report is unclear as to what DNA sample

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from appellant was used to compare his DNA to the evidence collected. He seems to

argue the trial court was required to presume the DPS report erroneously mixed up

appellant’s DNA with Frautschi’s oral swab listed on the submission form.

However, appellant presented no evidence that the previously tested items or

samples could be subjected to newer testing techniques that would lead to exculpatory

results. See TEX. CODE CRIM. PROC. art. 64.01(b)(2). Appellant’s counsel conceded at the

hearing that the DNA testing methods used in appellant’s case “appear[ed] to be the

same” testing methods used today. Indeed, the lab report shows the DPS laboratory used

“STR” testing which is one of the testing methods appellant requested in his motion for

post-conviction DNA testing. Because appellant failed to comply with his initial burden

under Article 64.01(b), he cannot invoke the “presumption” under Article 64.03(a)(2)(A). 3

See Reed, 541 S.W.3d at 769, 774 (analyzing whether appellant established elements

under Article 64.03(a) only after finding appellant met his initial burden under Article

64.01(b)); Routier, 273 S.W.3d at 256–57 (same).

As to whether the DPS report is “unclear,” we note “exculpatory results” under

Article 64.03(a)(2)(A) “means only results excluding the convicted person as the donor of

this material.” Reed, 541 S.W.3d at 774 (citing Holberg, 425 S.W.3d at 287). Thus, the

presumption under Article 64.03(a)(2)(A) does not require the trial court to presume

appellant’s DNA was mixed up with Frautschi’s DNA. See id. Moreover, whether the DPS

report is unclear is a fact question, and we afford almost total deference to the trial court’s

determination of fact issues. See Reed, 541 S.W.3d at 768–69; Holberg, 425 S.W.3d at

3 Appellant also did not allege or prove the previously tested items or samples were tested “at a

laboratory that ceased conducting DNA testing” due to an audit which “revealed the laboratory engaged in faulty testing practices.” TEX. CODE CRIM. PROC. art. 64.01(b)(2).

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285. Here, the DPS report indicated the evidence collected for DNA testing was compared

to separate DNA profiles from Ortman, appellant, and Frautschi. In this regard, we cannot

find the trial court abused its discretion.

Moreover, Frautschi was a listed suspect in DPS lab report, and the record is silent

as to why the State proceeded against appellant and not against Frautschi. Even if the

trial court presumed testing of the previously tested evidence would reveal exculpatory

results, the court was not provided with any information as to how the results would

connect to the crime or would have altered the outcome of the trial. See Reed, 541 S.W.3d

at 774 (“[Appellant] fails to articulate why the presumed exculpatory results of the items

he wanted tested would result in the jury finding him not guilty, as opposed to merely

‘muddying the waters’ as the trial judge concluded.”). Accordingly, we overrule appellant’s

sole issue. 4

IV. CONCLUSION

The trial court’s judgment is affirmed.

JON WEST

Justice

Do not publish.

TEX. R. APP. P. 47.2(b).

Delivered and filed on the

20th day of August, 2026.

4 Appellant argues in a sub-issue that “[t]he trial court made no findings with respect to whether

[he] met his burden under Article 64.01 as to chain of custody and biological evidence,” and without these findings, there is a presumption he met his burden to prove these elements. Because we overruled appellant’s first issue which was dispositive to the outcome of this appeal, we need not address this subissue. See TEX. R. APP. P. 47.1.

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