State v. Guilbert
Annotate this CaseA jury found Defendant guilty of capital felony, two counts of murder, and assault in the first degree. The Supreme Court affirmed the judgments of the trial court, holding (1) State v. Kemp and State v. McClendon, which state that expert testimony on the issue of reliability of eyewitness identification is disfavored, are expressly overruled; (2) accordingly, testimony by a qualified expert on the fallibility of eyewitness identification is admissible when that testimony would aid the jury in evaluating the state's identification evidence; (3) therefore, the trial court improperly precluded the defense from presenting certain expert testimony on the issue of eyewitness identification, but the impropriety was harmless; and (4) the trial court properly denied Defendant's motions for a mistrial and for a new trial, which stemmed from the state's delayed disclosure of certain allegedly exculpatory evidence, as Defendant was not so prejudiced by the late disclosure that he did not receive a fair trial.
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