To the Intake Committee and Clinic Directors,

I am writing to formally request that the Michigan Innocence Clinic review the 2002 murder conviction of Dennis Michael Salerno. This case is a prime candidate for your expertise as it rests on three pillars of wrongful conviction: unreliable "junk" science, profound prosecutorial misconduct, and a fundamental jurisdictional error that violates the due process of a Michigan citizen.

1. A Critical Shift in Science (MCR 6.502(G)) The primary physical evidence used to establish Michigan’s jurisdiction over a crime where the body was found in Ohio was "forensic geology." At trial, MSU geologists (Vogel et al.) claimed to "fingerprint" soil found on Mr. Salerno’s belongings to a specific landfill in Bowling Green, Ohio. Since 2002, the scientific consensus regarding soil comparison has shifted dramatically. Under current standards, the visual and chemical comparisons used in this trial lack the statistical rigor required for such a definitive match. This is precisely the "shift in science" envisioned by the 2018 amendment to MCR 6.502(G), and we believe modern mineralogical analysis would invalidate this "bridge" of evidence.

2. The Shadow of Stuart Dunnings III This case was prosecuted under the direct supervision of former Ingham County Prosecutor Stuart Dunnings III. As the Clinic is aware, Mr. Dunnings was subsequently sentenced to prison for a years-long pattern of misconduct in office and moral turpitude. His conviction cast a shadow over his 20-year tenure, suggesting a "win-at-all-costs" culture where evidence—including the use of highly incentivized jailhouse informants in the Salerno trial—was prioritized over the pursuit of truth.

3. The Jurisdictional Failure Without the now-disputed soil science, there is zero physical evidence that any element of this crime occurred in East Lansing, Michigan. Mr. Salerno was tried in a venue that may have lacked the legal authority to convict him. This case represents a systemic failure where the State of Michigan claimed power over a life based on a scientific theory that has not stood the test of time.

Dennis Salerno has maintained his innocence for over two decades. He has exhausted his direct appeals and is now in a position where only the intervention of a clinic with your specialized understanding of "non-DNA" innocence can correct this injustice.

We are prepared to provide the original trial transcripts, witness lists, and the specific geological reports for your review. We thank you for your time and for your unwavering commitment to the integrity of the Michigan justice system.

Sincerely,