Rodgers v. State’s Empirical Analysis

Citation profile

33 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 33 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. “If scientific, technical, or other specialized knowledge will assist the trier of fact to understand the evidence or to determine a fact in issue, a witness qualified as an expert by knowledge, skill, experience, training, or education may testify thereto in the form of an opinion or otherwise.”

   4 later decisions quote this exact passage · from the majority
   e.g. Coronado, David Cesar v. State · Latimer v. State

2. “(1) the witness qualifies as an expert by reason of his knowledge, skill, experience, teaming, or education; (2) the subject matter of the testimony is an appropriate one for expert testimony; and (3) admitting the expert testimony will actually assist the fact-finder in deciding the case.”

   3 later decisions quote this exact passage · from the majority
   e.g. Zack Eldred, Jr. v. State · Chakravarthy v. State

3. “Appellate courts may consider several criteria in assessing whether a trial court has clearly abused its discretion in ruling on an expert’s qualifications. First, is the field of expertise complex? The degree of education, training, or experience that a witness should have before he can qualify as an expert is directly related to the complexity of the field about which he proposes to testify. If the expert evidence is close to the jury’s common understanding, the witness’s qualifications are less important than when the evidence is well outside the jury’s own experience. For example, DNA profiling is scientifically complex; latent-print comparison (whether of fingerprints, tires, or shoes) is not. Second, how conclusive is the expert’s opinion? The more conclusive the expert’s opinion, the more important is his degree of expertise. Testimony that “a given profile occurred one time in 2.578 sextillion (2.578 followed by 21 zeroes), a number larger than the number of known stars in the universe (estimated at one sextillion)” requires a much higher degree of scientific expertise than testimony “that the defendant’s tennis shoe could have made the bloody shoe print found on a piece of paper in the victim’s apartment.” And third, how central is the area of expertise to the resolution of the lawsuit? The more dispositive it is of the disputed issues, the more important the expert’s qualifications are. If DNA is the only thing tying the defendant to the crime, the reliability of th”

   2 later decisions quote this exact passage · from the majority
   e.g. Stevenson v. State · Blackwell v. Wyeth