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699 KB
Extraction Summary
7
People
4
Organizations
1
Locations
7
Events
6
Relationships
7
Quotes
Document Information
Type:
Legal document
File Size:
699 KB
Summary
This document is a page from a legal filing, specifically page 7 of document 397 in case 1:20-cr-00330-PAE, filed on October 29, 2021. It outlines the legal standard for admitting expert testimony under the 'Daubert' framework, citing Federal Rule of Evidence 702 and numerous precedent cases. The text explains that a court must first assess an expert's qualifications and then determine if their testimony is both relevant and reliable, detailing several criteria for establishing reliability.
People (7)
| Name | Role | Context |
|---|---|---|
| Rainey | Litigant |
Party in the case Beech Aircraft Corp. v. Rainey, 488 U.S. 153, 169 (1988).
|
| Daubert | Litigant |
Party in the case Daubert, 509 U.S. at 597, which established the standard for expert testimony.
|
| Kidd | Litigant |
Party in the case United States v. Kidd, 385 F. Supp. 3d 259, 263 (S.D.N.Y. 2019).
|
| Romano | Litigant |
Party in the case United States v. Romano, 794 F.3d 317, 330 (2d Cir. 2015).
|
| Williams | Litigant |
Party in the case United States v. Williams, 506 F.3d 151, 160 (2d Cir. 2007).
|
| Amorgianos | Litigant |
Party in the case Amorgianos v. Nat’l R.R. Passenger Corp., 303 F.3d 256, 265 (2d Cir. 2002).
|
| Carmichael | Litigant |
Party in the case Kumho Tire Co. v. Carmichael, 526 U.S. 137, 150 (1999).
|
Organizations (4)
| Name | Type | Context |
|---|---|---|
| Beech Aircraft Corp. | company |
Party in the case Beech Aircraft Corp. v. Rainey, 488 U.S. 153, 169 (1988).
|
| United States | government agency |
Party in the cases United States v. Kidd, United States v. Romano, and United States v. Williams.
|
| Nat’l R.R. Passenger Corp. | company |
Party in the case Amorgianos v. Nat’l R.R. Passenger Corp., 303 F.3d 256, 265 (2d Cir. 2002).
|
| Kumho Tire Co. | company |
Party in the case Kumho Tire Co. v. Carmichael, 526 U.S. 137, 150 (1999).
|
Timeline (7 events)
Locations (1)
| Location | Context |
|---|---|
|
Mentioned in the citation for United States v. Kidd, 385 F. Supp. 3d 259, 263 (S.D.N.Y. 2019).
|
Relationships (6)
Parties in the court case Beech Aircraft Corp. v. Rainey.
Parties in the court case United States v. Kidd.
Parties in the court case United States v. Romano.
Parties in the court case United States v. Williams.
Parties in the court case Amorgianos v. Nat’l R.R. Passenger Corp.
Parties in the court case Kumho Tire Co. v. Carmichael.
Key Quotes (7)
"A witness who is qualified as an expert by knowledge, skill, experience, training, or education may testify in the form of an opinion or otherwise . . . ."Source
— Fed. R. Evid. 702
(Quoted to define the qualifications for an expert witness.)
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Quote #1
"At the first step of the Daubert inquiry, courts are instructed to consider the expert’s qualifications."Source
— United States v. Kidd
(Describing the initial step a court must take when evaluating expert testimony.)
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Quote #2
"will be not only relevant, but reliable."Source
— United States v. Romano
(Stating the two primary requirements for admissible expert testimony.)
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Quote #3
"that an expert’s testimony both rests on a reliable foundation and is relevant to the task at hand"Source
— Daubert
(Explaining the court's responsibility to ensure the validity of expert testimony.)
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Quote #4
"that the testimony is grounded on sufficient facts or data; (2) that the testimony is the product of reliable principles and methods; and (3) that the witness has applied the principles and methods reliably to the facts of the case."Source
— Rule 702
(Listing the three 'indicia of reliability' for expert testimony.)
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Quote #5
"has been subjected to peer review and publication"Source
— Daubert
(An additional factor offered by the Daubert case for evaluating scientific theory.)
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Quote #6
"known or potential rate of error."Source
— Daubert
(Another factor from the Daubert case for evaluating scientific theory.)
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Quote #7
Full Extracted Text
Complete text extracted from the document (2,080 characters)
Case 1:20-cr-00330-PAE Document 397 Filed 10/29/21 Page 7 of 84
579, 588 (1993) (quoting Beech Aircraft Corp. v. Rainey, 488 U.S. 153, 169 (1988)).
Under Daubert, a district court must first determine whether an expert is qualified. See
Fed. R. Evid. 702 (“A witness who is qualified as an expert by knowledge, skill, experience,
training, or education may testify in the form of an opinion or otherwise . . . .”); United States v.
Kidd, 385 F. Supp. 3d 259, 263 (S.D.N.Y. 2019) (“At the first step of the Daubert inquiry, courts
are instructed to consider the expert’s qualifications.”). Courts then must determine whether the
testimony “will be not only relevant, but reliable.” United States v. Romano, 794 F.3d 317, 330
(2d Cir. 2015); see Daubert, 509 U.S. at 597 (explaining that courts must ensure “that an expert’s
testimony both rests on a reliable foundation and is relevant to the task at hand”). On reliability,
Rule 702 identifies three “indicia of reliability”: (1) “that the testimony is grounded on sufficient
facts or data; (2) that the testimony is the product of reliable principles and methods; and (3) that
the witness has applied the principles and methods reliably to the facts of the case.” United
States v. Williams, 506 F.3d 151, 160 (2d Cir. 2007) (quoting Amorgianos v. Nat’l R.R.
Passenger Corp., 303 F.3d 256, 265 (2d Cir. 2002)). “[T]hese criteria,” however, “are not
exhaustive.” Id. Daubert itself, which “dealt with a scientific theory,” offered additional factors,
such as whether the theory “‘has been subjected to peer review and publication,’” and the
“‘known or potential rate of error.’” Romano, 794 F.3d at 330 (quoting Daubert, 509 U.S. at
593-94). And “there are many different kinds of experts, and many different kinds of expertise.”
Kumho Tire Co. v. Carmichael, 526 U.S. 137, 150 (1999). “[W]hether the specific expert
testimony focuses upon specialized observations, the specialized translation of those
observations into theory, a specialized theory itself, or the application of such a theory in a
Under Daubert, a district court must first determine whether an expert is qualified. See
Fed. R. Evid. 702 (“A witness who is qualified as an expert by knowledge, skill, experience,
training, or education may testify in the form of an opinion or otherwise . . . .”); United States v.
Kidd, 385 F. Supp. 3d 259, 263 (S.D.N.Y. 2019) (“At the first step of the Daubert inquiry, courts
are instructed to consider the expert’s qualifications.”). Courts then must determine whether the
testimony “will be not only relevant, but reliable.” United States v. Romano, 794 F.3d 317, 330
(2d Cir. 2015); see Daubert, 509 U.S. at 597 (explaining that courts must ensure “that an expert’s
testimony both rests on a reliable foundation and is relevant to the task at hand”). On reliability,
Rule 702 identifies three “indicia of reliability”: (1) “that the testimony is grounded on sufficient
facts or data; (2) that the testimony is the product of reliable principles and methods; and (3) that
the witness has applied the principles and methods reliably to the facts of the case.” United
States v. Williams, 506 F.3d 151, 160 (2d Cir. 2007) (quoting Amorgianos v. Nat’l R.R.
Passenger Corp., 303 F.3d 256, 265 (2d Cir. 2002)). “[T]hese criteria,” however, “are not
exhaustive.” Id. Daubert itself, which “dealt with a scientific theory,” offered additional factors,
such as whether the theory “‘has been subjected to peer review and publication,’” and the
“‘known or potential rate of error.’” Romano, 794 F.3d at 330 (quoting Daubert, 509 U.S. at
593-94). And “there are many different kinds of experts, and many different kinds of expertise.”
Kumho Tire Co. v. Carmichael, 526 U.S. 137, 150 (1999). “[W]hether the specific expert
testimony focuses upon specialized observations, the specialized translation of those
observations into theory, a specialized theory itself, or the application of such a theory in a
6
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