Case (cite)
People v. Richardson, 2020 IL App (4th) 200011-U (Il. App. 2021)
People v. Richardson, 2020 IL App (4th) 200011-U (Il. App. 2021)
Year
2021
State
Illinois
Type of proceeding
Appellate
Type of claim
Conflict of Interest
Type of claim (second claim)
Expert evidence ruling reversing or affirming on appeal:
Admitted
What was the ruling?
Remand
Type of evidence at issue:
Firearms identification
Defense or Prosecution Expert
Name of expert(s) who were the subject of the ruling
N/A
Summary of reasons for ruling
Court reversed Defendant's conviction for first degree murder and remanded for a new trial because Defendant did not knowingly waive a per se conflict of interest.
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
Kathryn Doolin, Carolyn Kersting
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
This was not a ruling on expert testimony; it was a ruling on the per se conflict of interest that Defendant did not intentionally waive. Defense counsel represented a prosectuion witness in unrelated criminal matters. No meaningful discussion of forensic evidence, other than to note that experts testified.