Case (cite)
United States v. Natson, 469 F.Supp.2d 1253 (M.D. Ga. 2007)
United States v. Natson, 469 F.Supp.2d 1253 (M.D. Ga. 2007)
Year
2007
State
Federal
Type of proceeding
Trial
Type of claim
Evidentiary
Type of claim (second claim)
Expert evidence ruling reversing or affirming on appeal:
Admitted
What was the ruling?
Other
Type of evidence at issue:
Firearms identification
Defense or Prosecution Expert
Prosecution
Name of expert(s) who were the subject of the ruling
Paul Tangren
Summary of reasons for ruling
the defendant challenged that the toolmark identification technique is inherently unreliable and therefore should be excluded but the court ruled that it is reliable (without giving much details or reasoning) reasoning that it holds under the five Daubert factors and that the expert in question here is qualified.
The jurisdiction’s standard for expert admissibility at the time – list all that apply: (Frye), (Daubert), (Post-2000 Rule 702), (Other)
Daubert
Second standard
Rule 702
Did lower court hold a hearing
Y
Names of prosecution expert(s) two testified at hearing
Tangren
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
N
Frye Ruling
N
Limiting testimony ruling
Language imposed by court to limit testimony
Ruling based in prior precedent / judicial notice
N
Daubert ruling emphasizing – which factors – (list 1-5)
All factors
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
Y
Ruling on 702(c) – the testimony is the product of reliable principles and methods
Y
Ruling on 702(d) – reliable application of principles and methods to the facts of the case
Y
Notes
interesting comparison with Green Court and Glynn Court