Abruquah v. State, 2020 WL 261722 (Md. Ct. Spec. App.)

Defendant first argued that the court erred in not granting a Frye-Reed hearing because firearms identification testimony is no longer widely accepted. The court disagreed because the trial court took judicial notice that firearms identification remains widely accepted. Second, the defendant argued that the expert should not have been allowed to testify that the bullet came from his gun due to the concerns set for the NAS2008, NAS2009, and PCAST. The court that this court had previously accepted firearms identification testimony, even after the publication of the NAS reports, and that the PCAST report explicitly says that admissibility of this kind of evidence is up to the courts. The court had already limited the experts testimony in line with other courts on this issue.