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Jackson v. State, 169 So.3d 1 (Ala. Crim. App. 2010)

Case (cite)
Jackson v. State, 169 So.3d 1 (Ala. Crim. App. 2010)
Year
2010
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
Heather Harrelson
Summary of reasons for ruling
Under Alabama law, "properly qualified expert should be permitted to testify whether a particular shell was fired from a specific firearm based upon his comparison of the distinctive marks on the shell with the physical features of the firearm." Therefore, it did not matter that the expert did not explain her methodology or the reliability of her methods.
The jurisdiction’s standard for expert admissibility at the time – list all that apply: (Frye), (Daubert), (Post-2000 Rule 702), (Other)
Ala. 702
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
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 (decision made under Alabama law)
Ruling on qualifications of expert
Y
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
Y? ("there is no indication that Harrelson's methodology is unreliable")+W75
Ruling on 702(d) – reliable application of principles and methods to the facts of the case
N

Notes

The court analyzes the admissiblity of fingerprint evidence right after the firearms testimony and analyzes fingerprints under 702, but does not mention 702 in the firearms discussion. Although the fingerprint analysis is also very brief