United States v. Paul
United States Court of Appeals for the Eleventh Circuit
175 F.3d 906 (11th Cir. 1999)
Sunonda Paul (defendant) was charged with extortion after being caught retrieving ransom money left in a bathroom per an anonymous note demanding it; FBI document examiner Larry Ziegler testified that Paul's handwriting samples matched the note, including identical misspellings of "restaurant" and the bank manager's name. Paul sought to counter Ziegler's testimony with law professor Mark Denbeaux, who taught evidence but had no formal training or practical experience in handwriting analysis; the district court admitted Ziegler's testimony but excluded Denbeaux's, and the jury convicted Paul, who appealed, challenging both rulings and the alleged prejudicial effect of Ziegler's testimony.
Whether a witness may testify as an expert in a given field if he does not have the requisite specialized knowledge, skill, experience, training, or education in that field.