Minor v. United States

A jury convicted Calvin Minor (defendant) of armed carjacking and related crimes. At trial, Crystal Nunnley identified Minor as the young man who pointed a gun at her outside of a convenience store, took her keys, and drove away in her car. Nunnley testified that she was terrified during and after the carjacking, that the incident lasted only seconds, and that visualizing her assailant’s gun helped her remember her assailant’s face. Minor appealed from his conviction, arguing that the trial court had erred by excluding expert testimony from Dr. Ronald Fisher, a psychology professor who would have testified about the reliability of eyewitness identifications. Fisher’s testimony was based upon social-science studies exploring factors that influence eyewitnesses’ abilities to accurately remember events, such as the length of time that the witness was exposed to the event or the presence of a gun. The appellate court remanded the case to the trial court to hold an evidentiary hearing regarding the admissibility of Fisher’s expert testimony. On remand, the trial court reaffirmed its exclusion of Fisher’s expert testimony. Although the trial court agreed with both parties that Fisher was qualified to testify as an expert, the court reasoned first that Fisher could not be absolutely certain that eyewitness-identification theories would always hold true for all people and second that the findings of the relevant scientific studies were not absolute. Minor again appealed from the trial court’s ruling.