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Jones v. United States, 27 A.3d 1130 (Ct. App. D.C. 2011)

Case (cite)
Jones v. United States, 27 A.3d 1130 (Ct. App. D.C. 2011)
Year
2011
State
District of Columbia
Type of proceeding
Appellate
Type of claim
Evidentiary
Expert evidence ruling reversing or affirming on appeal:
Admitted
What was the ruling?
No Error due to Harmless Error
Type of evidence at issue:
Firearms identification
Defense or Prosecution Expert
Prosecution
Name of expert(s) who were the subject of the ruling
Neal Morin, Michael Mulderig
Summary of reasons for ruling
Defendant challenged the trial court's denial of their request for a Frye hearing, arguing that if there had been a hearing, the defendant could have shown that this method of toolmark identificaiton is no longer generally accepted in the scientific community based on Adina Schwartz's article. The court held that even other courts that have held pretrial hearings and considered that article have found firearms identification evidence admissible, and that "nothing presented to the trial court (or to us) usggests that the pattern matching methodology is no longer generally accepted." On limited testimony: The court agrees that experts should be limited to testifying to a "reasonable degree of certainty," but does not make a desicion on the issue because the error is harmless in this case
The jurisdiction’s standard for expert admissibility at the time – list all that apply: (Frye), (Daubert), (Post-2000 Rule 702), (Other)
Frye
Did lower court hold a hearing
N (trial court denied request for Frye hearing)
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
Y
Limiting testimony ruling
N
Language imposed by court to limit testimony
(but does agree that experts should testify "to a reasonable degree of certainty")
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