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Williams v. State, 254 A.3d 556 (Md. App. 2021)

Case (cite)
Williams v. State, 254 A.3d 556 (Md. App. 2021)
Year
2021
State
Maryland
Type of proceeding
Appellate
Type of claim
Evidentiary
Expert evidence ruling reversing or affirming on appeal:
Admitted
What was the ruling?
Remand
Type of evidence at issue:
Firearms identification
Defense or Prosecution Expert
Prosection
Name of expert(s) who were the subject of the ruling
N/A
Summary of reasons for ruling
The court ordered a limited remand for the circuit court to determine whether it would reach the same conclusions as to the admissibility of the firearms examiner's expert testimony post-Rochkind because the court could not determine whether the circuit court abused its discretion under a standard that it did not consider.
The jurisdiction’s standard for expert admissibility at the time – list all that apply: (Frye), (Daubert), (Post-2000 Rule 702), (Other)
Md. Rule 5-702; Frye-Reed; Daubert; Rochkind
Did lower court hold a hearing
Y
Names of prosecution expert(s) two testified at hearing
N/A
Names of defense expert(s) who testified at hearing (or None).
N/A
Discussion of 2009 NAS Report (NAS2009) or PCAST report (PCAST)
PCAST
Discussion of error rates / reliability
N
Frye Ruling
N
Limiting testimony ruling
N
Language imposed by court to limit testimony
N
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
N
Ruling on 702(d) – reliable application of principles and methods to the facts of the case
N

Notes

Extensive discussion of Rochkind v. Stevenson standard