State v. Mcphaul

808 S.E.2d 294 304-05 (2017)

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Nature of the Case

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Facts

Tyler Lloyd was beaten with a baseball bat. P called in a fingerprint expert, Wood, to testify that D’s finger impressions matched fingerprints found on Lloyd’s truck and on a box of food found during the search of the house from where the online pizza order was made. D filed a motion to exclude that testimony under Daubert. Wood testified that she has worked as a latent fingerprint examiner since December 2007. According to Wood, each unique fingerprint contains distinguishing characteristics called 'minutia,' or 'Galton points.' Wood testified that it is possible to identify the source of a latent print by comparing the latent print with an individual's 'known impressions' and evaluating similarities between the prints' minutia points. Wood explained the examination procedure that she uses in determining whether a latent fingerprint matches a particular individual's known impressions. First, Wood identifies the latent print's pattern type and determines whether the print was formed by a finger or a palm. If the print contains sufficient identifiable minutia points, Wood compares the print against the individual's known impressions. She performs the examination under an optic camera, which allows her to enlarge the minutia points and view the prints side by side. Wood explained how she uses this procedure to ultimately conclude whether the prints were formed by the same individual. Wood testified that she uses the same examination technique as is commonly used in the field of latent print identification, and she employed this procedure while conducting her examination in this case. However, when Wood testified to her ultimate conclusions, she was unable to establish that she reliably applied the procedure to the facts of this case. D repeatedly objected to the foundation for Wood's opinion testimony and its admission pursuant to Rule 702(a). D was convicted and appealed. D renews those challenges on appeal.