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Commonwealth v. Lacastro, 2021 WL 3878593 (Pa. Sup. Ct. 2021)

Case (cite)
Commonwealth v. Lacastro, 2021 WL 3878593 (Pa. Sup. Ct. 2021)
Year
2021
State
Pennsylvania
Type of proceeding
Appellate
Type of claim
Evidentiary; Ineffective assistance of counsel
Expert evidence ruling reversing or affirming on appeal:
Admitted
What was the ruling?
Correct to Admit
Type of evidence at issue:
Firearms identification
Defense or Prosecution Expert
Prosecution
Name of expert(s) who were the subject of the ruling
Dale Wimer
Summary of reasons for ruling
Appellant argued that (1) the evidence was insufficient to sustain his convictions for first degree murder, (2) his trial counsel was ineffective in failing to object to the admission of crime scene photographs, (3) his trial counsel was ineffective in failing to hire an expert in firearms to testify on behalf of Appellant, (3) the cumulative impact of the multiple instances of counsel deprived Appellant of due process rights, and (4) the PCRA court erred in dismissing Appellant's PCRA petition without an evidentiary hearing. The Court found all claims meritless.
The jurisdiction’s standard for expert admissibility at the time – list all that apply: (Frye), (Daubert), (Post-2000 Rule 702), (Other)
N/A
Did lower court hold a hearing
Y
Names of prosecution expert(s) two testified at hearing
Dale Wimer
Names of defense expert(s) who testified at hearing (or None).
None
Discussion of 2009 NAS Report (NAS2009) or PCAST report (PCAST)
N
Discussion of error rates / reliability
N
Frye Ruling
N
Limiting testimony ruling
N
Language imposed by court to limit testimony
N/A
Ruling based in prior precedent / judicial notice
N
Daubert ruling emphasizing – which factors – (list 1-5)
N/A
Ruling on qualifications of expert
N
Ruling on 702(a) – the expert will help / assist the jury
N
Ruling on 702(b) – the testimony is based on sufficient facts or data
N
Ruling on 702(c) – the testimony is the product of reliable principles and methods
N
Ruling on 702(d) – reliable application of principles and methods to the facts of the case
N

Notes