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Kent v. State, 50 S.W.2d 817 (Tex. 1932)

Case (cite)
Kent v. State, 50 S.W.2d 817 (Tex. 1932)
Year
1932
State
Texas
Type of proceeding
Appellate
Type of claim
Evidentiary
Type of claim (second claim)
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
J.J. Smith and the sheriff
Summary of reasons for ruling
At defendant's murder trial, an expert testified that a pair of defendant's shoes almost perfectly matched the print at the crime scene. It was also offered into evidence that defendant was seen by witnesses in the vicinity of the crime, driving a car that fit the description of his uncle's car. An expert also testified that the shotgun shells were the same. Following his conviction, defendant moved for a new trial, alleging that he had discovered witnesses who had seen him in another location at the time of the crime. The court held that the trial court had properly admitted all of the testimony against defendant.
The jurisdiction’s standard for expert admissibility at the time – list all that apply: (Frye), (Daubert), (Post-2000 Rule 702), (Other)
Second standard
Did lower court hold a hearing
Y
Names of prosecution expert(s) two testified at hearing
J.J. Smith and the sheriff
Names of defense expert(s) who testified at hearing (or None).
Discussion of 2009 NAS Report (NAS2009)
Discussion of 2016 PCAST report (PCAST)
Discussion of error rates / reliability
N
Frye Ruling
N
Limiting testimony ruling
Language imposed by court to limit testimony
Ruling based in prior precedent / judicial notice
N
Daubert ruling emphasizing – which factors – (list 1-5)
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