Frank Sterling Case: False Confession, DNA, and Mark Christie

The Frank Sterling case is one of New York’s most cited wrongful conviction stories: a Rochester-area truck driver who spent nearly nineteen years in prison for the 1988 beating death of seventy-four-year-old Viola Manville, convicted almost entirely on a false confession pulled from him after a twelve-hour interrogation, and finally exonerated on April 28, 2010, when Touch DNA testing identified the real killer — a man who had gone on to murder a four-year-old girl while Sterling sat behind bars.¹

The Murder Sterling Was Accused Of

On November 29, 1988, Viola Manville was attacked while walking along an abandoned railroad bed near her home in Hilton, a suburb of Rochester in Monroe County. She was shot twice with a BB gun, struck with a piece of railroad tie, and beaten to death.¹ The case went cold for nearly three years before Monroe County Sheriff’s Office investigators reopened it in 1991.

Why Investigators Focused on Sterling

Sterling came onto investigators’ radar because of his brother. Glenn Sterling had previously been imprisoned for an attempted sexual assault on Manville, and detectives theorized that Frank killed her out of anger over Glenn’s absence from the family at Thanksgiving.¹ He was twenty-five, had no criminal record, and co-workers backed up his alibi.²

How the False Confession Was Produced

Sterling had just finished a thirty-six-hour truck-driving shift when he was brought in for questioning.³ The interrogation lasted roughly twelve hours, stretching from afternoon into the following morning.¹

Investigators Thomas Vasile and Patrick Crough used a series of suggestive techniques.⁴ They put Sterling on the floor with his feet propped on a chair, rubbed his back, and led him through a hypnotic relaxation exercise. At one point, an officer lay next to him, held his hand, and breathed deeply with him.⁵ They showed him crime scene photographs, walked him through specific details of the killing, told him the victim “deserved what she got,” and repeated that they were “here for you” and “still care for you.”¹

Sterling later said officers never asked him to describe what happened in his own words. They asked leading questions, and his answers were mostly “yes” and grunts.⁶ Eventually, exhausted, he began to shake and said, “I did it, I need help.” He recanted immediately afterward.¹

Of the nearly twelve hours in the interrogation room, police recorded only the final twenty minutes. Neither the trial court nor the jury ever saw how the crime’s details had actually made their way into Sterling’s mouth.⁵ The confession itself was full of errors: Sterling misidentified where the killing occurred, could not describe the weapon, and gave the wrong number of shots fired.³

Trial, Conviction, and an Ignored Lead

On September 29, 1992, a Monroe County jury convicted Sterling of second-degree murder. The prosecution’s case rested almost entirely on the videotaped confession.¹ Prosecutors argued that only the real killer would know the nonpublic details in Sterling’s statement — an argument that ignored the fact that investigators had supplied those details themselves.⁵ The jury deliberated for two days and asked repeatedly for reinstruction on the confession before returning a guilty verdict.

Sterling was sentenced to twenty-five years to life. Shortly after the verdict, defense counsel moved to set it aside based on new evidence that a Hilton teenager named Mark Christie had bragged to multiple people about killing Manville. The trial judge denied the motion, calling Christie’s statements “perverse braggadocio” and finding them not credible.²

What Mark Christie Did While Sterling Was in Prison

Christie remained free. In 1994, he abducted and strangled his four-year-old neighbor, Kali Ann Poulton.³ He pleaded guilty and received twenty-five years to life.⁷ That killing occurred while Sterling was imprisoned for the crime Christie had actually committed.

How DNA Finally Cleared Him

Rochester attorney Donald M. Thompson never believed the confession. He had represented Sterling once before, in a traffic case, and considered the statement “too inconsistent with the facts of the case.”² Together with the Innocence Project and attorney Vanessa Potkin, he spent more than fourteen years pursuing post-conviction relief.⁸

In 2006, the defense persuaded prosecutors to authorize Touch DNA testing on Manville’s clothing at Orchid Cellmark Laboratories. The technique detects skin cells and sweat, and the analysis pulled DNA from two spots on her clothing where an attacker would have grabbed her during the assault and while dragging her body. The profile excluded Sterling and matched Mark Christie.¹

In January 2010, Potkin and Richard Byington, an interrogation expert from John E. Reid and Associates, went to see Christie in prison. He initially deflected, telling Potkin he was not responsible for Sterling’s imprisonment because “Frank’s the one who talked.”⁹ Eventually, he gave a detailed confession containing facts not previously known to police or the public, which prosecutors then corroborated.¹⁰

On April 28, 2010, Sterling’s indictment was dismissed. He walked out after roughly eighteen years and nine months in prison.¹ In September 2011, Christie pleaded guilty to second-degree murder for killing Manville and was sentenced to twenty years to life, to run consecutively with his sentence for Kali Ann Poulton. He will not be eligible for parole for thirty years.¹¹

The Settlement

Sterling sued Monroe County and the City of Rochester, arguing that investigators had ignored evidence pointing at Christie and had engaged in misconduct that produced the false confession. In 2014, the parties settled for $8.625 million. Monroe County legislators unanimously approved a payment of just over $7 million, and the City of Rochester covered the rest. Sterling’s attorney Nick Brustin said the county had recognized “there was a terrible miscarriage of justice.”¹² A later state legislative document put his aggregate compensation at more than $10 million.¹³

Reforms His Case Drove

The case became a lever for interrogation-recording reform in New York. Then-Senator Eric Schneiderman cited Sterling while pushing for mandatory electronic recording of full interrogations and preservation of post-conviction DNA. Schneiderman also introduced the Actual Innocence Act of 2009, which would have created a freestanding legal ground for vacating a conviction based on reliable proof of actual innocence.¹⁰

Effective April 1, 2018, New York began requiring law enforcement to video record custodial interrogations for most serious non-drug felonies, including homicides.¹⁴ A failure to record can factor into a court’s admissibility ruling, and juries may be instructed to weigh the absence of a recording when evaluating voluntariness. The statute carves out exceptions for equipment malfunctions, spontaneous statements, and certain other circumstances.¹⁵ A pending Assembly bill, A04342, would replace those exceptions with a strict exclusionary rule barring any unrecorded confession from evidence. Its justification section cites Sterling’s case by name.¹³

Life After Prison

Freedom was disorienting. Sterling said early on that it felt “unreal.”²¹⁶¹⁷

Vanessa Potkin, who had spent years fighting for his freedom, said she was “so saddened to hear that Frank has passed away.” Donald Thompson reflected that the murder conviction had always been “inconsistent with his character.”¹⁶

1
Innocence Project. Frank Sterling
2
Democrat and Chronicle. Frank Sterling in Seneca, South Carolina
3
Innocence Project. 18 Years After Wrongful Conviction, New York Man Is Exonerated
4
Innocence Project. Sterling Case Shows Ripple Effects of Wrongful Convictions
5
Slate. Who Confesses to a Crime They Didn’t Commit
6
Innocence Project. “I Did It” — New York Magazine on False Confessions
7
San Diego Union-Tribune. DNA Clears NY Man Wrongly Convicted of 1988 Murder
8
NY Daily Record. Dedicated Defender Thompson Is on a Roll
9
New York Magazine. False Confessions
10
New York State Senate. After Rochester Man Cleared of Murder He Did Not Commit
11
Deseret News. NY Child Killer Gets 20 to Life for ’88 Slaying
12
Democrat and Chronicle. Frank Sterling Monroe County Wrongful Conviction Settlement
13
New York State Assembly. Bill A04342
14
New York State Division of Criminal Justice Services. Video Recording of Custodial Interrogations
15
NACDL. Recording Interrogations — New York
16
Innocence Project. In Memoriam: Frank Sterling
17
13WHAM. Frank Sterling, Greece Man Who Had Murder Conviction Cleared, Has Died