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State v. Celaya, 2016 WL 4256877 (Ct. App. Ariz. 2016)

Case (cite)
State v. Celaya, 2016 WL 4256877 (Ct. App. Ariz. 2016)
Year
2016
State
Arizona
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?
No Error due to Harmless Error
Type of evidence at issue:
Firearms identification
Defense or Prosecution Expert
Prosecution
Name of expert(s) who were the subject of the ruling
Not named
Summary of reasons for ruling
Defendant argues that the trial court erred in denying an evidentiary hearing on the NAS2009 report which he claims constituted newly discovered evidence. On remand, the court explains that the NAS report merely contradicts the forensic evidence presented at trial, but that the petitioner did not identify any tactical decisions made as a result of the strength of the evidence presented at trial and therefore the court was not required to consider the NAS report in conjunction with additional new alibi evidence. The court states that the petitioner is overstating the importance of the forensic evidence at trial and that it would not have altered the jury's verdict.
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
Names of defense expert(s) who testified at hearing (or None).
Discussion of 2009 NAS Report (NAS2009)
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

Note: The AZ Supreme Court remanded the case for an evidentiary hearing to consider whether the NAS2009 report constituted newly discovered evidence after the court of appeals declined to consider the issue. The trial court held an evidentiary hearing and concluded that the NAS2009 report was cumulative to evidence already presented at trial and would not have altered the jury’s verdict. This opinion is the court of appeals opinion on appeal of the remanded trial court ruling.

 

 

 

A footnote describing the trial: “The evidence offered by Celaya varies on this point—he identifies a 2013 letter from the United States Department of Justice containing a statement by the Federal Bureau of Investigation (FBI) that the “science regarding firearms examinations does not permit examiner testimony that a specific gun fired a specific bullet to the exclusion of all other guns in the world” but does permit testimony that a specific gun fired a specific bullet “to a reasonable degree of scientific certainty.” But one of the experts called by Celaya at the evidentiary hearing went considerably further than the FBI, testifying the “strongest scientifically defensible opinion … would be that a specific firearm could not be eliminated as the … firing platform for particular bullets or cartridge cases.””