State v. Pennington’s Empirical Analysis
1990
Citation profile
8 federal appellate · 2 district · 118 state decisions
How this case has been cited
Cited by 128 later decisions — most recently December 2017 · most notably Howerton v. Arai Helmet, Ltd. (2004), Connecticut v. Porter (1997)
8 federal appellate · 2 district · 118 state decisions — followed in 21 states
Later decisions citing this case, by decade. The current decade is in progress, and our corpus holds fewer opinions from the most recent years, so the latest bars are undercounted — not a real decline.
Relationships
Relies on Frye v. United States · State v. Bullard · People v. Castro · Spencer v. Commonwealth · 542 So. 2d 1330 - In re Amendment to Florida Rule of Criminal Procedure 3.191
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 128 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“"A new scientific method of proof is admissible at trial if the method is sufficiently reliable. State v. Bullard , 312 N.C. 129 , 148 , 322 S.E.2d 370 , 381 (1984); 1 Brandis on North Carolina Evidence, § 86, at 385 (1988). Reliability of a scientific procedure is usually established by expert testimony, and the acceptance of experts within the field is one index, though not the exclusive index, of reliability. See State v. Bullard , 312 N.C. at 147 , 322 S.E.2d at 380 ; State v. Peoples , 311 N.C. 515 , 532 , 319 S.E.2d 177 , 187 (1984). Thus we do not adhere exclusively to the formula, enunciated in Frye v. United States , 293 F. 1013 (D.C. Cir. 1923), and followed in many jurisdictions, that the method of proof 'must be sufficiently established to have gained general acceptance in the particular field in which it belongs.' Id. at 1014 . Believing that the inquiry underlying the Frye formula is one of the reliability of the scientific method rather than its popularity within a scientific community, we have focused on the following indices of reliability: 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. State v. Bullard , 312 N.C. at 150 -51 , 322 S.E.2d at 382."”
7 later decisions quote this exact passage““The admissibility of any such evidence remains subject to attack. Issues pertaining to relevancy or prejudice may be raised. For example, expert testimony may be presented to impeach the particular procedures used in a specific test or the reliability of the results obtained. In addition, traditional challenges to the admissibility of evidence such as the contamination of the sample or chain of custody questions may be presented. These issues relate to the weight of the evidence. The evidence may be found to be so tainted that it is totally unreliable and, therefore, must be excluded.””
4 later decisions quote this exact passage
How this case has been treated — in progress
Whether each later court followed, distinguished, criticized, or overruled this decision. The treatment classification (task #35) runs highest-cited cases first and lights up here as it reaches this one.