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State v. Riley, 568 B.W.2d 518 (Minn. 1997)

Case (cite)
State v. Riley, 568 B.W.2d 518 (Minn. 1997)
Year
1997
State
Minnesota
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
Defense or Prosecution Expert
Prosecution
Name of expert(s) who were the subject of the ruling
Papke
Summary of reasons for ruling
Defendant argued that the expert's opinion to "a reasonable degree of scientific certainty" amounted to an opinion that the suspected murder weapon was the source of the casings "to the exclusion of all other guns" and should have been excluded or limited to "consistent with." The court disagreed and held that the expert did not conclusively testify that the shells could not have come from any other fun and that the "reasonable degree of scientific certainty" terminology has been approved by the court before in other qualitative testimony contexts (DNA).
The jurisdiction’s standard for expert admissibility at the time – list all that apply: (Frye), (Daubert), (Post-2000 Rule 702), (Other)
702
Did lower court hold a hearing
N
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) or PCAST report (PCAST)
N/A
Discussion of error rates / reliability
Frye Ruling
N
Limiting testimony ruling
Y
Language imposed by court to limit testimony
"reasonable degree of scientific certainty"
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

“Papke did not testify conclusively that the shells could not have come from any other gun except the Smith & Wesson, and therefore, the Spencer rule is inapplicable here. Cf., State v. Bloom, 516 N.W.2d 159, 168 (Minn.1994) (noting that some courts approve of such conclusive testimony in the fingerprint context). Moreover, it was not error for the trial court to permit Papke to state his opinion to a “reasonable degree of scientific certainty.” We have approved of this terminology in the presentation of qualitative testimony such as offered here. See id. (expressly sanctioning the use of “reasonable scientific certainty” in the context of DNA evidence). Therefore, it was proper for Papke to state his opinion that to a “reasonable degree of scientific certainty,” the Smith & Wesson handgun was the source of the collected shell casings.”