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Edward Easley

Other Child Sex Abuse Exonerations with Perjury or False Accusation
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On January 20, 1993, 37-year-old Edward Easley was arrested in Shasta County, California on charges of sexually molesting his girlfriend’s niece when she was seven years old.

The arrest was the culmination of an investigation that began in June 1992. At the time, Easley and his girlfriend, Sharon Rhoades, were living in Castella, California. Across a bridge from their house, but within eyesight, was the trailer where Rhoades’s sister, Mickey Mitchell, lived with her daughter, Nichole. On June 8, 1992, Mickey’s physical therapist reported to the Shasta County Sheriff’s office that Nichole had possibly been molested.

During an interview with Shasta County Detective Madeline Wade and Child Protective Services worker Dawn De Hart, Nichole, who was nine years old, said that Easley had touched her “back private with his front private” on more than one occasion when she was seven years old..

Two physicians examined Nichole. Dr. Kathleen Mannion found no scars, fissures, or injuries, but concluded that the findings were “compatible with a history of probable sexual abuse.” Dr. Perry Pugno reported that the medical history was “consistent with multiple episodes of penetration of the vagina by an object approximating the size of an adult finger or larger. In addition, the examination is consistent with multiple episodes of traumatic anal penetration in the past.”

When sheriff’s detectives interviewed Easley, he denied molesting the girl.

Nichole wept as she described at a preliminary hearing in Shasta County Superior Court how Easley molested her. Following the hearing, Easley’s attorney advised him that he could face more than 30 years in prison if he went to trial, or he could plead guilty and get a 10-year prison sentence. Although he maintained he was innocent, Easley pled no-contest. He did not want Nichole to go through a trial, and he did not want to spend 30 years in prison for a crime he did not commit.

In December 1996, when Nichole was 13, she told her aunt, Sharon Rhoades, that Easley had not molested her and that she wanted to tell the Shasta County District Attorney’s office. Rhoades’s then-boyfriend, Robin Streeter, drove them to the prosecutor’s office, where Nichole said that Easley had not molested her. She refused to say, however, who had molested her. This recantation was not disclosed to Easley or his defense attorney.

Over the years, Nichole continued to tell people that Easley was innocent. She finally told a relative that her cousin, Caleb, and his friend had molested her. The relative, Jack Mitchell, called the Shasta County Sheriff’s office and was told to call the district attorney’s office. Mitchell later said that he called several times over four or five days until a secretary said that the “case was taken care of and that there wouldn’t be any further need of evidence of any kind and …to quit bothering them.” No report of Mitchell’s calls was ever disclosed to Easley.

In 1999, Easley was released from prison on parole and required to register as a sex offender. After his release, Sharon Rhoades told him that Nichole had recanted. Easley sought help from the Northern California Innocence Project (NCIP) at Santa Clara University Law School. In 2007, NCIP filed a state law petition for a writ of habeas corpus, arguing that his conviction was based on false testimony and that he was factually innocent. A judge denied the petition without a hearing.

However, in 2008, the California Court of Appeals ordered an evidentiary hearing. At the hearing in 2009, Nichole, who by then was working as a bank teller, testified that her cousin, Caleb, and Caleb’s friend had molested her. Nichole testified that she was afraid of her mother, and that she suffered from encopresis as a child. Encopresis is a medical condition that occurs when children develop a pattern of withholding their excrement and as a result develop very large bowel movements that are painful to pass. Nichole testified that she had soiled her underwear and hid it from her mother. When her mother discovered the underwear, she associated it with molestation. That's when her mother and Caleb’s mother forced her to blame Easley to protect Caleb.

Nichole also testified that she was a good friend of Caleb’s ex-wife. After she confided to her what had happened, Caleb called her. She said he started to cry and said, “I’m so sorry I hurt you.”

Caleb testified and confirmed that he apologized. He claimed, however, that the apology was “not for physically doing anything with her,” but because “I was involved in the troubles that were troubling her at the time, so I…I apologized for whatever happened.” He also testified, “Nichole is credible” when she said that Easley never molested her.

Dr. James Crawford, medical director for the Center for Child Protection as Benioff Children’s Hospital in Oakland, testified that he had examined the reports by the two physicians and concluded that the medical evidence did not indicate one way or another whether Nichole was abused. Crawford testified that the evidence did not support the prosecution’s assertion that the medical examinations revealed extensive physical damage to Nichole that could only have been the result of repeated conduct by an adult and that her encopresis was a result of being sexually abused.

In April 2009, the trial court denied the false testimony claim. It ruled that Nichole’s testimony at the preliminary hearing could have been inaccurate, but not necessarily false because she could have believed what she was saying at the time. The judge also denied the actual innocence claim because “a reasonable jury could convict Mr. Easley.”

The judge said Easley’s lawyers failed to meet the standard under California law that new evidence “point unerringly to innocence” and “completely undermine the prosecution’s case.” Yet the judge also stated, “However, if the standard is whether a reasonable jury would convict Mr. Easley, based on all the evidence, including the recantation, this court, by a preponderance of the evidence, finds that there would not have been a conviction.”

NCIP lawyers then filed an original petition for a writ of habeas corpus in the California Court of Appeal, but that was denied. In January 2010, NCIP filed an original petition for writ of habeas corpus in the California Supreme Court. The court denied that petition in July 2010 because Easley was no longer in custody, and he therefore had no legal right to file such a petition.

In the fall of 2016, the California Legislature passed NCIP-supported bills that allowed people no longer in custody to challenge their convictions and eliminated the standard that the evidence must “point[] unerringly to innocence.” The new law says that if it’s “more likely than not” that substantial new evidence would have made a difference, a conviction must be set aside.

After the laws went into effect on January 1, 2017, NCIP attorney Paige Kaneb and former NCIP attorney Maitreya Badami filed a new petition on Easley’s behalf. The change in the standard was particularly helpful to Easley because the judge, in denying his petition in 2009, had specifically ruled that Easley had met the standard for “more likely than not.”

On August 31, Easley’s conviction was vacated and the charges were dismissed.

– Maurice Possley

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Posting Date: 9/10/2017
State:California
County:Shasta
Most Serious Crime:Child Sex Abuse
Additional Convictions:
Reported Crime Date:1990
Convicted:1993
Exonerated:2017
Sentence:10 years
Race:Caucasian
Sex:Male
Age at the date of crime:35
Contributing Factors:False or Misleading Forensic Evidence, Perjury or False Accusation
Did DNA evidence contribute to the exoneration?:No