201 N.C. App. 707 - State v. Meadows’s Empirical Analysis

Citation profile

14 state decisions

Most-quoted passages

The sentences later courts lift from this opinion, ranked by how many decisions quote each — the parts of the opinion doing the work. These counts are smaller than the citation total above because most of the 14 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. “Where, however, the trial court is without precedential guidance or faced with novel scientific theories, unestablished techniques, or compelling new perspectives on otherwise settled theories or techniques, a different approach is required. Here, the trial court should generally focus on the following nonexclusive indices of reliability to determine whether the expert’s proffered scientific or technical method of proof is sufficiently reliable: the expert’s use of established techniques, the expert’s professional background in the field, the use of visual aids before the jury so that the jury is not asked to sacrifice its independence by accepting the scientific hypotheses on faith, and independent research conducted by the expert. Within this general framework, reliability is thus a preliminary, foundational inquiry into the basic methodological adequacy of an area of expert testimony. This assessment does not, however, go so far as to require the expert’s testimony to be proven conclusively reliable or indisputably valid before it can be admitted into evidence.”

   2 later decisions quote this exact passage
   e.g. 203 N.C. App. 741 - State v. Rambert · 216 N.C. App. 519 - State v. Jones

2. “We are not aware of any cases in which the NarTest machine has been recognized as an accepted method of analysis or identification of controlled substances in North Carolina or in any other jurisdiction in the United States. [Therefore, we] cannot base any conclusions as to [the] reliability of the NarTest machine upon [Partain's] testimony or judicial notice.”

   1 later decision quote this exact passage
   e.g. 203 N.C. App. 741 - State v. Rambert

3. “However, the NarTest machine has not been designated as an approved method of identification of controlled substances by the State of North Carolina or any agency of the State . . . [and] no agency of the State of North Carolina issues any sort of certification in use of the NarTest machine.”

   1 later decision quote this exact passage
   e.g. 203 N.C. App. 741 - State v. Rambert