Commonwealth v. Janqdhari, 225 A.3d 1190

Officers in this Commonwealth are regularly admitted as experts to identify factory-standard firearms and ammunition, though these are items with which firearms owners might be familiar. See, e.g., Commonwealth v. Cousar, 638 Pa. 171, 154 A.3d 287, 295 (Pa. Super. 2017) (admitting officer as firearms identification expert to identify .357 revolver); Commonwealth v. Ramos, 573 Pa. 605, 827 A.2d 1195, 1198 (Pa. Super. 2003) (admitting officer as firearms identification expert to identify caliber of fatal bullet). Here, Officer Kinniry offered a factual description that could alternatively lead an everyday citizen to picture either an illegal, ersatz firearms accessory13Link to the text of the note or trash. See N.T. Trial, 12/13/17, at 59 ("a black cylinder . . . wrapped in black tape."). Nothing indicates that the item described would be identifiable as a silencer to the ordinary, law-abiding firearms owner, let alone the "ordinary layman." Griffith, supra at 1238. Consequently, the court erred by admitting [*17] Officer Kinniry's lay opinion. Id.Nevertheless, the court's error was harmless.