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Reed v. State, 391 A.2d 364

Case (cite)
Reed v. State, 391 A.2d 364
Year
1978
State
Maryland
Type of proceeding
Appellate
Type of claim
Evidentiary
Expert evidence ruling reversing or affirming on appeal:
Admitted
What was the ruling?
Error to Admit, Remand
Type of evidence at issue:
Voice Comparison ("Voiceprint")
Defense or Prosecution Expert
Prosection
Name of expert(s) who were the subject of the ruling
Dr. Oscar Tosi, Detective Sergeant Lonnie Smrkovski
Summary of reasons for ruling
The appellate court's judgment of conviction against defendant was reversed and remanded for a new trial because the court held that the admission of the voiceprint evidence was in error. The court held that the testimony based on the voiceprint, which had not gained general acceptance in the scientific community, was not admissible. The court concluded that the voiceprint process had not been sufficiently tested and accepted to qualify its results for use in the courts, and the reliability of the conclusions based on the data obtained from the process was uncertain.
The jurisdiction’s standard for expert admissibility at the time – list all that apply: (Frye), (Daubert), (Post-2000 Rule 702), (Other)
Kelly Frye
Did lower court hold a hearing
Y
Names of prosecution expert(s) two testified at hearing
Dr. Oscar Tosi, Detective Sergeant Lonnie Smrkovski
Names of defense expert(s) who testified at hearing (or None).
N/A
Discussion of 2009 NAS Report (NAS2009) or PCAST report (PCAST)
N/A
Discussion of error rates / reliability
Y
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
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