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678 KB
Extraction Summary
4
People
4
Organizations
1
Locations
4
Events
2
Relationships
4
Quotes
Document Information
Type:
Legal document
File Size:
678 KB
Summary
This page from a legal filing discusses the standards for the admissibility of expert witness testimony. It cites several key legal precedents, including Daubert and Kumho Tire, to outline the court's responsibility to ensure an expert's opinion is reliable and based on sound methodology. The document also specifies that even if testimony meets these standards, it can be excluded under other rules, such as Rule 704, which prohibits experts in criminal cases from opining on a defendant's mental state.
People (4)
| Name | Role | Context |
|---|---|---|
| Carmichael | Party in a legal case |
Mentioned as a party in the case Kumho Tire Co. v. Carmichael.
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| Electra | Party in a legal case |
Mentioned as a party in the case Electra v. 59 Murray Enterprises, Inc.
|
| Amorgianos | Party in a legal case |
Mentioned as a party in a case cited for standards on expert testimony.
|
| Daubert | Party in a legal case |
Mentioned as a party in a landmark Supreme Court case that set standards for expert testimony.
|
Organizations (4)
| Name | Type | Context |
|---|---|---|
| City of N.Y. | Government agency |
Mentioned as a party in a cited legal case.
|
| Kumho Tire Co. | Company |
Mentioned as a party in the case Kumho Tire Co. v. Carmichael.
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| 59 Murray Enterprises, Inc. | Company |
Mentioned as a party in the case Electra v. 59 Murray Enterprises, Inc.
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| The Supreme Court | Government agency |
Mentioned as the court that set forth factors for determining reliability of expert testimony in the Daubert case.
|
Timeline (4 events)
1999
The case of Kumho Tire Co. v. Carmichael, 526 U.S. 137, which is cited for the scope of Rule 702.
2005
A case involving the City of N.Y., 414 F.3d. 381, which quotes the Kumho Tire case.
2021
The case of Electra v. 59 Murray Enterprises, Inc., 987 F.3d 233, which is cited for the standard of examining an expert's analysis.
Locations (1)
| Location | Context |
|---|---|
|
Mentioned as part of the name of a party in a legal case, 'City of N.Y.'.
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Relationships (2)
Parties in the legal case Kumho Tire Co. v. Carmichael.
Parties in the legal case Electra v. 59 Murray Enterprises, Inc.
Key Quotes (4)
"To decide ‘whether a step in an expert’s analysis is unreliable, the district court should undertake a rigorous examination of the facts on which the expert relies, the method by which the expert draws an opinion from those facts, and how the expert applies the facts and methods to the case at hand.’"Source
— Court opinion in Electra v. 59 Murray Enterprises, Inc.
(Quoted to explain the court's duty in evaluating expert testimony.)
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Quote #1
"If an expert’s opinions rest “on data, a methodology, or studies that are simply inadequate to support the conclusions reached, Daubert and Rule 702 mandate the exclusion of that unreliable opinion testimony.”"Source
— Court opinion in Amorgianos
(Stating the requirement to exclude unreliable expert testimony.)
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Quote #2
"Rule [702] applies its reliability standard to all ‘scientific,’ ‘technical,’ or ‘other specialized’ matters within its scope."Source
— Court opinion in Kumho Tire
(Describing the broad applicability of the reliability standard under Rule 702.)
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Quote #3
"[i]n a criminal case, an expert witness must not state an opinion about whether the defendant did or did not have a mental state or condition that constitutes an"Source
— Rule 704
(Providing the text of Rule 704, which limits expert testimony in criminal cases regarding a defendant's mental state.)
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Quote #4
Full Extracted Text
Complete text extracted from the document (1,989 characters)
Case 1:20-cr-00330-PAE Document 386 Filed 10/29/21 Page 9 of 24
v. City of N.Y., 414 F.3d. 381, 396 (2d Cir. 2005) (quoting Kumho Tire Co. v. Carmichael, 526 U.S. 137, 152 (1999)). “To decide ‘whether a step in an expert’s analysis is unreliable, the district court should undertake a rigorous examination of the facts on which the expert relies, the method by which the expert draws an opinion from those facts, and how the expert applies the facts and methods to the case at hand.’” Electra v. 59 Murray Enterprises, Inc., 987 F.3d 233, 254 (2d Cir. 2021) (quoting Amorgianos, 303 F.3d at 267). If an expert’s opinions rest “on data, a methodology, or studies that are simply inadequate to support the conclusions reached, Daubert and Rule 702 mandate the exclusion of that unreliable opinion testimony.” Amorgianos, 303 F.3d at 266.
The Supreme Court in Daubert set forth several factors for the court to consider in determining reliability: “(1) whether a theory or technique can be (and has been) tested; (2) whether the theory or technique has been subjected to peer review and publication; (3) a technique’s known or potential rate of error, and the existence and maintenance of standards controlling the technique’s operation; and (4) whether a particular technique or theory has gained ‘general acceptance’ in the relevant scientific community” Amorgianos, 303 F.3d at 266 (cleaned up). “Rule [702] applies its reliability standard to all ‘scientific,’ ‘technical,’ or ‘other specialized’ matters within its scope.” Kumho Tire, 526 U.S. at 147-48.
Assuming an expert’s opinions clear the relevancy and reliability hurdles of Daubert and Rule 702, the court must nevertheless exclude the evidence if it violates Rule 704, Rule 403, or Rule 404. Daubert, 509 U.S. at 595.
Rule 704 provides that “[i]n a criminal case, an expert witness must not state an opinion about whether the defendant did or did not have a mental state or condition that constitutes an
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