United States v. Ruvalcaba-Garcia, No. 17-50288 (9th Cir. 2019)
Annotate this CaseThe Ninth Circuit affirmed defendant's conviction for illegally reentering the United States after having been removed. The panel held that, although the district court abused its discretion by admitting an expert's testimony regarding a fingerprint taken during the 2015 removal proceedings without first finding it relevant and reliable, the error was harmless because the record was sufficient to determine that the expert testimony was relevant and reliable under Federal Rule of Evidence 702.
Court Description: Criminal Law. The panel affirmed a conviction for illegally reentering the United States after having been removed, in a case in which the defendant argued that the district court abused its discretion by admitting expert testimony that a fingerprint taken during the underlying removal proceedings belonged to the defendant. The panel held that the district court abused its discretion by failing to make an explicit reliability finding before admitting the fingerprint analyst’s expert testimony, as required under Daubert v. Merrill Dow Pharm, Inc., 509 U.S. 579 (1993), and Fed. R. Evid. 702, but that the error was harmless because the record is sufficient to determine that the testimony had a reliable basis in the knowledge and experience of the relevant discipline. The panel addressed remaining arguments in an accompanying memorandum disposition. UNITED STATES V. RUVALCABA-GARCIA 3
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