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Edwards v. State, 81 A.2d 631 (Ct. App. Md. 1951)

Case (cite)
Edwards v. State, 81 A.2d 631 (Ct. App. Md. 1951)
Year
1951
State
Maryland
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 A. Frazier
Summary of reasons for ruling
Defendant argued that he testimony was unreliable because the expert first testified that there were too few marks to make comparisons and a few months later testified that the bullets were fired from the same gun. The court disagreed. The expert had admitted that there were other types of guns that could have made the same class characteristics and explained how the rifling from a pistol could be removed, which the defendant later admitted to doing. The court found that there was sufficient evidence for the lower court to have concluded that the rifling was removed after the bullet had been fired.
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
N
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
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