“Well, can’t we stipulate as to Mr. Groton’s qualifications? The Court has a full calendar tomorrow.”
“I think, if the Court please, that the interests of my client require...”
“Very well, but the Court warns you, Mr. Mason, that it is not going to be patient with any tactics utilized purely for the purpose of delay. This is a preliminary hearing. It is not a trial in front of a jury. The Court is fully familiar with Mr. Groton’s actual qualifications. The Court has heard him testify on dozens of occasions. Moreover, I think that Counsel are quite familiar with Mr. Groton’s qualifications. Take the stand, Mr. Groton.”
Groton returned to the witness stand.
Mason said, “In regard to this precipitin test for human blood, you are familiar with the mechanics of the test?”
“Naturally.”
“Can you describe to the Court just what...?”
“The Court doesn’t need any description,” Judge Mundy interrupted impatiently. “The Court is fully familiar with the process. By repeated injections of human blood an animal develops a defensive mechanism which immunizes him against that type of blood. If, therefore, a serum from the blood of that animal is maintained in a test tube and human blood is added to it, there is a reaction which results in a precipitation. That’s all there is to it.”
“Very well, Your Honor,” Mason said, still keeping his smiling good humor. “I would like to have the witness testify to that rather than the Court.”
Judge Mundy frowned angrily, then said, “Very well, ask the witness if you want to, but the Court knows it and you know it, and every person who has had any experience with scientific crime detection knows it.”
“That is generally the case, is it?” Mason asked Groton.
“That is a general description, yes.”
“Now then,” Mason said, “when was this test first developed? Just answer the question briefly.”
“If you don’t mind,” Groton said, “and so it will clear the matter in your own mind, Mr. Mason, I would like to tell you something about the precipitin test.”
“Go right ahead.”
“About the turn of the century,” Groton said, “a gentleman named Uhlenhuth, a leading German worker in serology, first showed that if you inject a rabbit with the blood serum of another animal species, say man, you will iso-immunize him, that is, you will produce in his (rabbit) blood a substance that will react (or show up) only with the same animal species with which he has been injected, man’s blood.
“Wassermann was one of the many who confirmed Uhlenhuth’s dictum, and the test began to be used as a method for identifying human blood.
“Professor Nuttall, an American serologist, who was a professor at Cambridge University, England, took up the immense task of making a complete determination of the scope and field of the various tests, and in 1904 published his work in book form.
“Professor Nuttall produced anti-sera from rabbits injected in turn with blood from every known animal the world over, and in no case did he find any exceptions to the dictum that the test was specific, i.e., sera from rabbits injected with elephant blood reacted only with elephant blood, etc.”
Groton glanced at the judge and smiled, and the judge returned his smile as much as to say, “I guess that will put this lawyer in his place.”
Mason said, “That’s very interesting, Mr. Groton. Did you know that several of the German investigators had stated that the blood of the primates sometimes gave reactions weakly simulating human blood reactions?”
“I believe that there is something to that effect in some of these books.”
“And methods have been very much improved since the period of Uhlenhuth and Professor Nuttall?”
“Oh yes.”
“Now then, are you acquainted with Dr. R. B. H. Gradwohl?”
“I have heard of him. I am not acquainted with him.”
“He is the director of the St. Louis Police Laboratory in St. Louis, Missouri?”
“I believe that is right.”
“Are you familiar with his experiments conducted during 1951 and 1952 with the improved technique now available?”
“No, sir. I am not.”
“Are you familiar with a paper which was published first in the Laboratory Digest, Volume 15, February 1952, pages 4, 5 and 6, in which Dr. Gradwohl followed up this early suggestion and made precipitin tests with the blood of apes?”
“Why — now that you mention it, I believe that I did have the matter called to my attention at one time.”
“I submit that if you are going to testify in this matter you had better keep up with the latest scientific advances in it,” Mason said. “You will find that Dr. Gradwohl, with the new improved equipment, made a series of tests with the blood of chimpanzees, and found that he obtained exactly the same reaction in the precipitin test with chimpanzee blood that he got with human blood.
“To complete the chain of evidence he then injected rabbits with chimpanzee blood, producing an anti-chimpanzee testing serum, and found that this gave identical results with both chimpanzee and human blood samples.”
“Well, I didn’t know that!” Groton exclaimed.