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United States v. Williams, 506 F.3d 151 (2nd Cir. 2007)

Case (cite)
United States v. Williams, 506 F.3d 151 (2nd Cir. 2007)
Year
2007
State
2nd Circuit
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
Michelle Kuehner
Summary of reasons for ruling
Defendant argues that the court erred in denying him a Daubert hearing and in failing to adequately inquire into the reliability of the firearms identification methodology. The court held that the trial court did not err in denying a Daubert hearing because a hearing is not required to ascertain the reliability of the expert's methodology, particularly if there is a sufficient basis for allowing the testimony. The court also holds that Daubert was satisfied in this case. The trial court, when denying the Daubert hearing, provided sufficient analysis that the expert was qualified due to her experience and training and adequately considered the use of this evidence in other cases.The court however that the opinion should not "be taken as saying that any proffered ballistic expert should be routinely admitted," because courts still must undertake their gatekeeping function regardless of whether the testimony has long been assumed reliable under Frye and Rule 702. (see notes for quotes)
The jurisdiction’s standard for expert admissibility at the time – list all that apply: (Frye), (Daubert), (Post-2000 Rule 702), (Other)
Daubert; 702
Did lower court hold a hearing
N (trial court denied request for Daubert hearing)
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
N (but trial court favorably cites to Santiago)
Daubert ruling emphasizing – which factors – (list 1-5)
overall reliability
Ruling on qualifications of expert
Y
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
Y
Ruling on 702(d) – reliable application of principles and methods to the facts of the case
N

Notes

We do not wish this opinion to be taken as saying that any proffered ballistic expert should be routinely admitted. Daubert did make plain that Rule 702 embodies a more liberal standard of admissibility for expert opinions than did Frye v. United States, 293 F. 1013, 1014 (D.C.Cir.1923) . . . . But this shift to a more permissive approach to expert testimony did not abrogate the district court’s gatekeeping function. Nimely v. City of New York, 414 F.3d 381, 396 (2d Cir.2005). Nor did it “grandfather” or protect from Daubert scrutiny evidence that had previously been admitted under Frye. . . . Thus, expert testimony long assumed reliable before Rule 702 must nonetheless be subject to the careful examination that Daubert and Kumho Tire require.