Case (cite)
Watkins v. Commonwealth, 331 S.E.2d 422 (Va. 1985)
Watkins v. Commonwealth, 331 S.E.2d 422 (Va. 1985)
Year
1985
State
Virginia
Type of proceeding
Appellate
Type of claim
Evidentiary
Type of claim (second claim)
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
William E. Conrad
Summary of reasons for ruling
Watkins contends that the testimony of William E. Conrad, an expert in forensic science, was patently incredible so as to preclude submission of the case to the jury. Conrad stated that he was certain one of the bullets removed from the victim's body was fired from Watkins's pistol; he said there was "no margin of error." This positive statement merely affects the weight of his testimony; it does not necessarily invalidate or even weaken the results of his ballistics testing.
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
Y
Names of prosecution expert(s) two testified at hearing
William E. Conrad
Names of defense expert(s) who testified at hearing (or None).
None
Discussion of 2009 NAS Report (NAS2009)
N
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)
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