exon-erations, twenty-one percent of wrongful convictions were based on confessions that were made by or attributed to the defendant); see generally Richard Leo & Richard J. Ofshe, The Consequences of False Confessions: Deprivations of Liberty and Miscarriages of Justice in the Age of Psychological Interrogation, J. of Crim.L. & Criminology, Winter 1998 (reporting statistics on the unreliability of confessions). 7 . The majority in Henera did not set forth the standard that a person must reach for a truly persuasive showing of actual innocence. However, in Schlup, the Supreme Court resulted in the exoneration of David Vasquez, who had pled guilty to the crime and had been sentenced to 35 years in prison. See 1996 Report at 73. 9 . See Toney v. Gammon, 79 F.3d 693, 700 (8th Cir.1996) (<HOLDING>); Watkins v. Miller, 2000 WL 680418, *1
holding that district court abused its discretion by denying plaintiffs motion to file fourth amended complaint holding that the district court abused its discretion by denying the habeas petitioners motion to conduct dna testing which was unavailable at trial holding that district court had not abused its discretion in denying plaintiffs motion to amend complaint holding trial court abused its discretion by refusing to conduct hearing and render decision on motion holding that bia abused its discretion in denying motion to reopen