United States v. Adams

Odell Adams (defendant) was accused of shooting someone at a Portland bar. When police found two handguns at Adams’s house, a .40 caliber Taurus and a .40 caliber Ruger, they submitted the guns for forensic comparison to shell casings found at the scene. The National Integrated Ballistic Information Network initially concluded that the .40 caliber casings were not from Adams’s guns. However, when police requested a second comparison, the organization determined the casings matched Adams’s Taurus. Police then had a third comparison performed by Travis Gover, a forensic scientist at the Oregon State Police Crime Lab. Gover used a common methodology known as the AFTE methodology. It involved first comparing the casings’ physical characteristics with the firearm’s characteristics, such as caliber and manufacturer features. Second, the tested gun was fired to create exemplar shell casings for comparison. The examiner would determine whether there was sufficient agreement between the exemplar casings and tested casings to deem them a match. Although there were objective aspects of the comparison, there were no quantified objective criteria for what constituted sufficient agreement. Consequently, an examiner’s ultimate conclusion as to whether there was a match was largely subjective, being based on an examiner’s personal training and knowledge. Applying that AFTE methodology, Gover concluded that the shell casings were a match to Adams’s Taurus. Adams moved to limit Gover’s testimony under the Daubert standard, arguing that the AFTE method was insufficiently reliable. The district court considered the motion.