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State v. Favela, 323 P.3d 716 (Ariz. Ct. App. 2014)

Case (cite)
State v. Favela, 323 P.3d 716 (Ariz. Ct. App. 2014)
Year
2014
State
Arizona
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:
Fingerprint
Defense or Prosecution Expert
Prosecution
Name of expert(s) who were the subject of the ruling
Does not name
Summary of reasons for ruling
Defendant argued the trial court erred in admitting expert testimony about the latent palm print the police found at the scene because it did not comply with the requirements of Rule 702, Ariz. R. Evid. The appellate court found that the defendant presented no novel challenge or argument to suggest a change in fingerprint technology or circumstance between Moon v. State (1921) and this case would justify a change in Arizona's rule because of the shift to the Daubert standard. Accordingly, our supreme court's conclusion in Moon about fingerprint evidence still applies: given the proper foundation, expert testimony on matching fingerprint evidence is admissible because it is reliable.
The jurisdiction’s standard for expert admissibility at the time – list all that apply: (Frye), (Daubert), (Post-2000 Rule 702), (Other)
Post-2000 Rule 702; Daubert
Did lower court hold a hearing
N*
Names of prosecution expert(s) two testified at hearing
N/A
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
Y
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)
2; 3; 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
Y
Ruling on 702(d) – reliable application of principles and methods to the facts of the case
Y

Notes