State v. Hurst, 828 So.2d 1165 (La. Ct. App. 2002)

Defense called a civil engineer to testify about the difference between types of bullets. Although the witness had gone to ballistics school, the trial court held that he was not a ballistics expert. On appeal, the court confirmed that the witness was not a ballistics expert, stating that "experience alone may be sufficient to qualify a person as an expert," but the witness here did not inspect firearms as an occupation, had not done research on ballistics or bullet size, and did not present evidence that he had ever been qualified as an expert in a criminal case.