United States v. Smithers

United States Court of Appeals for the Sixth Circuit

212 F.3d 306 (6th Cir. 2000)

Relevant factsFree

James Smithers (defendant) was charged with bank robbery, and three eyewitnesses identified him at trial as the robber. Smithers wanted to introduce expert testimony about factors that can distort eyewitness accuracy. Without holding a hearing on the relevance and reliability of that testimony under Daubert v. Merrell Dow Pharmaceuticals, the trial court simply excluded it. Smithers was convicted and appealed.

IssueFree

Whether a trial court must conduct a Daubert hearing before ruling on the admissibility of expert testimony about the accuracy of eyewitness identifications.

Holding & reasoning

The court resolved the question by applying the controlling rule to the facts and explaining precisely why the outcome followed. Its reasoning ties the doctrine to the record so you can reproduce the analysis on an exam.

Procedural history, concurrence & dissent

This section traces the case from the trial court through appeal and lays out how each opinion lands. Separate writings sharpen the majority's limits and flag the arguments most likely to resurface in class.

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