Precedents Cited and Their Influence

• W. Va. Code § 53-4A-7(c) (1994): Requires circuit courts in habeas cases to make “specific findings of fact and conclusions of law” concerning each contention and to state the grounds of decision. This statute is the backbone of the Supreme Court’s insistence on detailed, issue-by-issue adjudication.
• State ex rel. Watson v. Hill, 200 W. Va. 201, 488 S.E.2d 476 (1997): Syllabus point 1 is quoted to reaffirm that § 53-4A-7(c) mandates specificity in habeas orders. It directly supports vacatur here due to the absence of specific findings on the suppression and DNA-expert issues.
• Province v. Province, 196 W. Va. 473, 473 S.E.2d 894 (1996): Establishes that general or conclusory findings require vacatur and remand. Footnote 19 underscores the necessity of explaining the court’s reasoning to enable the appellate court to “determine the correctness” of the decision. The Court applies this principle to conclude that it is “unable” to review the suppression ruling.
• Dennis v. State of West Virginia, Division of Corrections, 223 W. Va. 590, 678 S.E.2d 470 (2009) and State ex rel. Vernatter v. Warden, W. Virginia Penitentiary, 207 W. Va. 11, 528 S.E.2d 207 (1999): Reinforce that failure to make specific findings and conclusions on habeas issues typically necessitates remand. These cases confirm that the defect is not a technicality; it is jurisdictionally consequential for appellate review.
• State v. Joseph C., No. 19-0584, 2020 WL 5269751 (W. Va. Sept. 4, 2020) (memorandum decision): Illustrates the Court’s consistent practice of vacating where an order lacks the findings necessary for meaningful review.
• State v. Redman, 213 W. Va. 175, 578 S.E.2d 369 (2003) and Fayette County National Bank v. Lilly, 199 W. Va. 349, 484 S.E.2d 232 (1997) (overruled on other grounds by Sostaric v. Marshall, 234 W. Va. 449, 766 S.E.2d 396 (2014)): Confirm that a court may incorporate findings by reference, but the incorporated findings must consist of facts that are relevant, determinative, and undisputed for the case at hand. The Court applies this law to hold that lifting findings from the co-defendant’s case—where the DNA evidence materially differed—does not satisfy the requirement.
• Georgia v. Randolph, 547 U.S. 103 (2006): Central to the suppression challenge. Randolph holds that a warrantless search is invalid as to a physically present co-occupant who objects, notwithstanding another co-occupant’s consent. The Court does not decide the merits of this Fourth Amendment claim; instead, it faulted the habeas order for failing to address the claim with specific findings and legal analysis.
• Smith v. Hedrick, 181 W. Va. 394, 382 S.E.2d 588 (1989): Cited to clarify that refusal of a criminal appeal in 2007 did not adjudicate the merits. This history explains why the suppression issue remains open for proper habeas adjudication.
• Losh v. McKenzie, 166 W. Va. 762, 277 S.E.2d 606 (1981): Provides the “Losh checklist” framework for organizing habeas claims. Although not outcome-determinative here, it underscores the expectation that habeas issues be cataloged and resolved claim by claim with specific findings.

Legal Reasoning

The Supreme Court’s reasoning proceeds from a single, controlling premise: meaningful appellate review in habeas cases is impossible without clear, issue-specific findings of fact and conclusions of law. That premise is codified in § 53-4A-7(c) and entrenched by Watson, Province, Dennis, and Vernatter.

Applying that law, the Court identifies two independent deficiencies in the circuit court’s order:

1. Suppression of hotel-room evidence: The order lacks any legal analysis or fact-finding addressing whether the search was lawful, including the trial court’s pretrial justifications (third-party consent via Karen Sue Neider under “actual or apparent authority” and “search incident to arrest”). Without findings about the circumstances of consent, the presence or objection of occupants, or the scope and timing of any search incident to arrest, the Supreme Court cannot evaluate the habeas suppression claim—especially in light of Randolph’s rule governing co-occupant consent.
2. DNA-expert motion: The circuit court purported to dispose of Spears’s request for a new DNA expert by adopting a 2018 order from co-defendant Woods’s habeas case. While incorporation by reference is permissible, Redman and Lilly make clear that the adopted findings must be relevant, determinative, and undisputed for the current case. They were not. Spears’s case involved a mixed DNA profile on a t-shirt (potentially from Spears, Woods, and/or a victim), and—unlike Woods’s case—did not include a positive DNA identification tying Spears to a separate t-shirt. Because the evidentiary posture differed materially, petitioner-specific findings are required to evaluate whether a new DNA expert is warranted.

From these deficiencies, vacatur follows as a matter of course under Province and related cases. The Court also emphasizes a remedial directive: the circuit court must produce a “detailed and comprehensive order” resolving each claim with the specificity necessary to permit meaningful review should an appeal follow.

Impact and Prospective Significance

This decision does not announce a novel substantive standard; instead, it forcefully reaffirms and sharpens longstanding requirements for habeas orders in West Virginia. Its practical effects are significant:

• Heightened rigor in habeas adjudication: Circuit courts must resolve each Losh-ground contention with explicit factual findings, applicable legal standards, and reasoned conclusions. Boilerplate denials, silence on material issues, or generic references to the record will prompt vacatur and remand.
• Limits on incorporation by reference: Courts may not shortcut petitioner-specific analysis by adopting findings from another case—even a co-defendant’s—unless those findings address facts that are relevant, determinative, and undisputed for the petitioner’s case. Differences in evidentiary strength (e.g., a positive DNA match in one case versus a mixture in another) can be dispositive on whether incorporation is proper.
• Fourth Amendment suppression claims in habeas: When suppression claims are raised, circuit courts must address the precise legal theories (third-party consent, apparent authority, co-occupant objection under Randolph, and any “incident to arrest” arguments), make credibility determinations, and set out the facts supporting each legal conclusion. This case signals that suppression issues cannot be dismissed without articulated analysis.
• DNA expert funding and evaluation: The Court flags that laboratory findings and statistical inferences are highly case-specific. A request for expert assistance requires analysis tailored to the nature of the DNA evidence at issue (mixture vs. single-source, strength of population frequency estimates, and whether a positive identification exists). Courts must explain why an expert is or is not necessary in the petitioner’s case.
• Appellate efficiency through thorough trial-level orders: Although the decision remands, its broader effect should be fewer remands over time: detailed orders preserve judicial resources by enabling the Supreme Court to reach the merits without first sending cases back for findings.