Houston v. Delaware
Annotate this CaseDefendant Naifece Houston was charged with drug offenses following a traffic stop, and moved to suppress evidence on various grounds, including that the arresting officers impermissibly extended the stop to allow time for a drug-sniffing dog to arrive. In his motion to suppress, defendant asked the superior court to hold a Daubert hearing so that he could contest the admissibility of testimony from one of the arresting officers that he could detect an odor at the scene emanating from the defendant’s car - a “chemically smell” that the officer associated with large amounts of cocaine. Because the officer’s testimony was based on his training and experience as a police officer, according to defendant, it was “expert in nature,” triggering the trial court’s gatekeeping function under Daubert and its progeny. The superior court disagreed, concluding that the officer’s testimony was not based on scientific, technical, or other specialized knowledge, but, rather, was lay opinion testimony admissible under Delaware Rule of Evidence 701. On that rationale, defendant appealed, arguing the superior court erred. And had defendant’s motion been granted, he contended the State would have been left with no evidence that he was guilty of the drug offenses with which he was charged. The Delaware Supreme Court concluded that both defendant and the State, and ultimately the Superior Court, mistakenly framed the issue in the proceedings below as hinging upon the admissibility of the officer’s testimony under the rules of evidence governing opinion testimony. "Thus, the true question before the superior court was whether the challenged testimony was sufficiently reliable to justify the officer’s suspicion that there was cocaine in the defendant’s car." The Supreme Court concluded the trial court’s admission of the officer’s testimony was not an abuse of discretion. Thus, judgment was affirmed.
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