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U.S. v. Dunn, 2021 WL 2143054 (D. Minn. 2021)

Case (cite)
U.S. v. Dunn, 2021 WL 2143054 (D. Minn. 2021)
Year
2021
State
Minnesota
Type of proceeding
Trial
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
Travis Melland
Summary of reasons for ruling
First, the Court rejects Defendant's assertion that Melland's testimony should be excluded because the Government failed to timely disclose all relevant evidence regarding Melland. Indeed, the Government had timely disclosed the reports regarding the ballistics testing as soon as it received them, as well as offered the defense to meet with Melland and any other Government expert before trial. Second, the Defendant argues that the Court should hold a Daubert hearing so that the defense can challenge the admissibility of Melland's testimony. The Court concluded that no Daubert hearing was necessary because courts routinely find that firearm and toolmark identifications are reliable.
The jurisdiction’s standard for expert admissibility at the time – list all that apply: (Frye), (Daubert), (Post-2000 Rule 702), (Other)
Daubert; FRE 702
Did lower court hold a hearing
NA
Names of prosecution expert(s) two testified at hearing
Travis Melland
Names of defense expert(s) who testified at hearing (or None).
None
Discussion of 2009 NAS Report (NAS2009) or PCAST report (PCAST)
N
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
Y
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

Good discussion heavily relying on U.S. v. Black (2015)