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State v. Woodworth, 941 S.W.2d 679 (Mo. Ct. App. W.D. 1997)

Case (cite)
State v. Woodworth, 941 S.W.2d 679 (Mo. Ct. App. W.D. 1997)
Type of proceeding
Type of claim
Type of claim (second claim)
Expert evidence ruling reversing or affirming on appeal:
What was the ruling?
Correct to Admit
Type of evidence at issue:
Firearms identification
Defense or Prosecution Expert
Name of expert(s) who were the subject of the ruling
Garrison, Clayton
Summary of reasons for ruling
Mark claims the trial court erred in allowing the State's firearms experts to testify regarding the ballistics tests conducted on the bullets and Claude Woodworth's gun and on the general manufacture of firearms. He argues that, because the witnesses did not personally conduct any tests or experiments on the manufacturing process or specifically observe the manufacture of Claude Woodworth's pistol, their opinions were speculative and based on hearsay. The Court found that The three witnesses were established as qualified firearms experts without challenge from defendant. With regard to the testimony he now attacks, all three experts had extensively studied the field of firearms and were familiar with books and studies on the general manufacture of firearms. Experts Garrison and Clayton testified that they had personally observed the manufacturing process at various arms factories over the course of their careers. Therefore, the trial court did not abuse its discretion in allowing these arms experts to offer their opinions on the manufacturing process and the likelihood that Claude Woodworth's pistol fired the recovered bullets.
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
Names of prosecution expert(s) two testified at hearing
Garrison, Clayton
Names of defense expert(s) who testified at hearing (or None).
Discussion of 2009 NAS Report (NAS2009)
Discussion of 2016 PCAST report (PCAST)
Discussion of error rates / reliability
Frye Ruling
Limiting testimony ruling
Language imposed by court to limit testimony
Ruling based in prior precedent / judicial notice
Daubert ruling emphasizing – which factors – (list 1-5)
Ruling on qualifications of expert
Ruling on 702(a) – the expert will help / assist the jury
Ruling on 702(b) – the testimony is based on sufficient facts or data
Ruling on 702(c) – the testimony is the product of reliable principles and methods
Ruling on 702(d) – reliable application of principles and methods to the facts of the case