Skip to content

Hinton v. State, 172 So.3d 338

Case (cite)
Hinton v. State, 172 So.3d 338
Year
2011
State
Alabama
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
Both
Name of expert(s) who were the subject of the ruling
Andrew Payne
Summary of reasons for ruling
After the Alabama Supreme Court remanded the denial of defendant's postconviction relief petition for findings on whether defense counsel's firearms expert was qualified, the trial court made such findings. The appellate court held the trial court properly found the witness was qualified because the court (1) thoroughly examined the witness's testimony and, from that testimony, found the witness had the necessary knowledge, skill, and experience to qualify as an expert and (2) applied the proper standard, which was whether the witness had acquired knowledge beyond that of an average layperson.
The jurisdiction’s standard for expert admissibility at the time – list all that apply: (Frye), (Daubert), (Post-2000 Rule 702), (Other)
Ala. R. Crim. Pro. 32; Strickland v. Washington
Did lower court hold a hearing
Y
Names of prosecution expert(s) two testified at hearing
N/A
Names of defense expert(s) who testified at hearing (or None).
Payne
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