State v. Guilbert
Supreme Court of Connecticut
306 Conn. 218 (2012)
After William Robinson was shot at a bar, Brady Guilbert (defendant) was seen running from the scene, and two other men were later found shot in a crashed car. Robinson identified Guilbert as the shooter, and two witnesses who knew Guilbert personally, plus a third witness who did not know him but recognized him from a news photo, also identified him. Before trial, Guilbert sought to introduce expert testimony on how stress and after-the-fact information affect memory and eyewitness accuracy, but the trial court excluded it based on precedent holding that jurors already understand these factors. Guilbert was convicted and appealed.
Whether expert testimony on the fallibility of eyewitness identification is admissible when that testimony would assist the jury in evaluating the identification.