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U.S. v. Santiago, 199 F.Supp.2d 101 (S.D.N.Y. 2002)

Case (cite)
U.S. v. Santiago, 199 F.Supp.2d 101 (S.D.N.Y. 2002)
Year
2002
State
Federal District Court, Southern District of NY
Type of proceeding
Trial
Type of claim
Evidentiary
Expert evidence ruling reversing or affirming on appeal:
Admitted
What was the ruling?
Other; Trial court
Type of evidence at issue:
Firearms identification
Defense or Prosecution Expert
Prosecution
Name of expert(s) who were the subject of the ruling
Joseph Amato
Summary of reasons for ruling
The court said that it is "etremely unlikely" that a juror would have the same ability to match images of bullets that a ballistics expert would, so the expert's testimony would assist the jurors. Further, the court said that the qualifications and methodology of the expert could be challenged by the defense through voire dire.
The jurisdiction’s standard for expert admissibility at the time – list all that apply: (Frye), (Daubert), (Post-2000 Rule 702), (Other)
FRE 702; Daubert
Did lower court hold a hearing
N/A
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
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
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

The Court has not conducted a survey, but it can only imagine the number of convictions that have been based, in part, on expert testimony regarding the match of a particular bullet to a gun seized from a defendant or his apartment. It is the Court’s view that the Supreme Court’s decisions in Daubert and Kumho Tire, did not call this entire field of expert analysis into question