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Douglas v. State, 163 So.2d 477 (Ct. App. Ala. 1963) (later reversed on other grounds)

Case (cite)
Douglas v. State, 163 So.2d 477 (Ct. App. Ala. 1963) (later reversed on other grounds)
Year
1963
State
Alabama
Type of proceeding
Appellate
Type of claim
Evidentiary
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
Robert B. Finley
Summary of reasons for ruling
The court held that the expert's opinion that the bullets were fired from the same gun was "properly predicated" due to another Alambama case that held it was "proper for a jury to compare an 'evidence shell' with two 'test shells' fired from the evidence gun." Further, the court notes that this test could not have been done in court, and that the expert demonstrated his "path of research" through showing exhibits with large photographs of the evidence shell and the test shell.
The jurisdiction’s standard for expert admissibility at the time – list all that apply: (Frye), (Daubert), (Post-2000 Rule 702), (Other)
Kyzer v. State, 33 So.2d 885
Did lower court hold a hearing
N/A
Names of prosecution expert(s) two testified at hearing
Names of defense expert(s) who testified at hearing (or None).
Discussion of 2009 NAS Report (NAS2009) or PCAST report (PCAST)
N/A
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
Y
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