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State v. Benton, 413 A.2d 104 (R.I. 1980)

Case (cite)
State v. Benton, 413 A.2d 104 (R.I. 1980)
Year
1980
State
Rhode Island
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; ballistics
Defense or Prosecution Expert
Prosection
Name of expert(s) who were the subject of the ruling
Richard C. Wilkinson
Summary of reasons for ruling
Defendant argues that the trial court erred in admitting certain opinion testimony by the state's ballistics expert because (1) it was error to permit him to state an opinion about the conclusiveness of his test, and (2) his testimony about the conclusiveness of his test was irrelevant, since the probative value of the testimony does not depend upon the view that the individual witness takes of his own performance, skills or expertise. The court affirms thr trial court's ruling, as the trial court exercises wide discretion in determining the admissibility of an expert's opinion testimony. Although made in the context of his own ballistics test, the expert expressed the degree of credibility that experts in general attribute to the method he used, not his view of his own performance, skills or epertise. This testimony was therefore probative of a material issue.
The jurisdiction’s standard for expert admissibility at the time – list all that apply: (Frye), (Daubert), (Post-2000 Rule 702), (Other)
State v. Vaccaro
Did lower court hold a hearing
Y
Names of prosecution expert(s) two testified at hearing
Richard C. Wilkinson
Names of defense expert(s) who testified at hearing (or None).
None
Discussion of 2009 NAS Report (NAS2009) or PCAST report (PCAST)
N/A
Discussion of error rates / reliability
N
Frye Ruling
N
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