Imprisoned for a Crime You Didn’t Commit

Imagine being imprisoned for a crime you didn’t commit, then spending decades trying to prove your innocence. Christopher Dunn’s case shows how hard that fight can be. In his April 2023 article, “Is Punishing Innocent People Unconstitutional?,” Austin Sarat examined the legal barriers keeping Dunn in a Missouri prison. Dunn has since been freed, but his case still raises troubling questions about how courts address evidence of innocence.

Dunn was convicted in 1991 of the 1990 murder of Ricco Rogers in St. Louis. The prosecution relied on two young witnesses who later recanted their testimony. His case underscores why the Sixth Amendment right to effective assistance of counsel matters: defense lawyers need the time and resources to investigate the evidence against their clients.

In 2020, Missouri Circuit Court Judge William Hickle found that the evidence established Dunn’s innocence but denied relief under precedent limiting freestanding actual-innocence claims in state habeas proceedings to death-penalty cases. That restriction did not foreclose every route to relief. Missouri later enacted Section 547.031, allowing prosecutors to seek to overturn convictions based on evidence of innocence or constitutional error. That separate process became the route to Dunn’s release.

In Herrera v. Collins (1993), the U.S. Supreme Court explained that newly discovered evidence of innocence generally does not, by itself, provide a basis for federal habeas relief without an independent constitutional violation. The Court assumed, without deciding, that a sufficiently persuasive showing of innocence might bar an execution if no state process were available to hear the claim. It found Herrera’s evidence insufficient. The difficulty of challenging a conviction also has a local counterpart in Emmanuel Jean’s challenge to his Miami murder conviction.

Dunn ultimately won relief in Missouri’s courts. His convictions were overturned in July 2024, and he was released on July 30 after more than 34 years in prison. In May 2026, a Missouri appeals court affirmed the decision overturning his convictions. The Innocence Project’s account of Christopher Dunn’s case traces that long fight for freedom.

The story of Christopher Dunn is a stark reminder of the flaws in our criminal justice system. As criminal defense lawyers, we must always be vigilant in fighting for our clients’ rights and ensuring that the innocent are not punished for crimes they did not commit. The pursuit of justice is not just about defending the accused; it’s about upholding the principles that our legal system was built upon.