Skip to content

People v. Simmons, 66 N.E.3d 360 (Ill. 2016) [EXPLICITLY OVERRULE JONES]

Case (cite)
People v. Simmons, 66 N.E.3d 360 (Ill. 2016) [EXPLICITLY OVERRULE JONES]
Year
2016
State
Illinois
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
Brian Mayland
Summary of reasons for ruling
Here the expert testified on the methodology/process of comparing the bullets and the ultimate conclusion that the bullets matched without specifying what individual characteristics he saw that led him to the conclusion. The court held that the testimony is still admissible; the incompletion affects only its strengh.
The jurisdiction’s standard for expert admissibility at the time – list all that apply: (Frye), (Daubert), (Post-2000 Rule 702), (Other)
Ill. 702;
Did lower court hold a hearing
N/A
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
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
Y
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

almost the same fact pattern as in Jones but comp. different result – Jones is not good law anymore in Illinois