State v. McPhaul

Juan McPhaul (defendant) was charged with crimes including assault with intent to rob and murder after McPhaul and another man allegedly severely beat a Domino’s Pizza delivery driver with a metal bat. At trial, the State of North Carolina’s (plaintiff’s) evidence included the delivery driver’s stolen property that had been recovered from McPhaul’s residence, an aluminum baseball bat found underneath the residence next door to McPhaul’s, and descriptions of the suspects given by the delivery driver and a confidential informant. The state also showed that McPhaul’s residence was located close to the unsecured wireless network that had been used to place the Domino’s order. The state also presented testimony from Trudy Wood, a fingerprint expert, who testified that McPhaul’s fingerprint impressions matched latent fingerprints found on the delivery driver’s truck and a Domino’s chicken-wing box seized from McPhaul’s residence. McPhaul moved to exclude Wood’s testimony, but the trial court allowed Wood to testify. Wood told the jury that she followed common latent-fingerprint-identification procedures in performing her analysis. She said that in general, when examining fingerprints, she compares the pattern types and known minutia points of the latent fingerprints with the suspect’s known fingerprint impressions until she is sure that the fingerprints match. However, when the state asked Wood about the specific latent fingerprints on the truck and chicken-wing box, she did not explain to the jury how she applied those commonly accepted general procedures to reach her conclusions that the fingerprints matched McPhaul’s. Rather, she said only that her conclusions were based on her training and her experience in using the general procedures. The jury convicted McPhaul, and he appealed to the North Carolina Court of Appeals. One of McPhaul’s arguments on appeal was that the trial court erred in admitting Wood’s testimony.