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Williams v. State, 2017 WL 4946865 (Tex. Crim. App. 2017)

Case (cite)
Williams v. State, 2017 WL 4946865 (Tex. Crim. App. 2017)
Year
2017
State
Texas
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
James Jeffress
Summary of reasons for ruling
(court did not give a detailed analysis merely says the expert's testimony "demonstrated" that it was admissible)
The jurisdiction’s standard for expert admissibility at the time – list all that apply: (Frye), (Daubert), (Post-2000 Rule 702), (Other)
702; Daubert
Did lower court hold a hearing
Y
Names of prosecution expert(s) two testified at hearing
Jeffress
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
Y
Frye Ruling
N
Limiting testimony ruling
N
Language imposed by court to limit testimony
N/A
Ruling based in prior precedent / judicial notice
N
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
Y
Ruling on 702(d) – reliable application of principles and methods to the facts of the case
N

Notes

on error rate: “[the expert] acknowledged that a precise casework error rate could not be measured. But he pointed out that consecutive-manufacture and proficiency studies provided error rates in the context of controlled studies. Those known error rates could then be used to estimate casework error rate.”

 

on the subjectivity of firearms examination: “[the] implementation of professional standards and protocols, periodic lab audits and proficiency testing, and the independent review of the comparisons in each case by a second examiner, helped counteract the subsjective elements of an examiner’s conclusions.”