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State v. Samonte, 928 P.2d 1 (Haw. 1996)

Case (cite)
State v. Samonte, 928 P.2d 1 (Haw. 1996)
Year
1996
State
Hawaii
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
Judith Christensen
Summary of reasons for ruling
The court found that the trial court did not abuse its discretion in holding the expert was qualified because she had been trained by the HPD and had performed comparisons of casings to determine if they were from a specific weapon several times and had been qualified by a court to do so once.
The jurisdiction’s standard for expert admissibility at the time – list all that apply: (Frye), (Daubert), (Post-2000 Rule 702), (Other)
HRE 702; 703; Maelega ("In determining whether a litigant has satisfied these two prongs with respect to proffered scientific evidence, we utilize five factors: (1) the evidence will assist the trier of fact to understand the evidence or to determine a fact in issue; (2) the evidence will add to the common understanding of the jury; (3) the underlying theory is generally accepted as valid; (4) the procedures used are generally accepted as valid; (5) the procedures were applied and conducted properly in the present instance.")
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
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
Y
Ruling on 702(a) – the expert will help / assist the jury
Y
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