United States v. Baines

Robert Baines (defendant) was charged with multiple drug- and weapons-related crimes. Law enforcement pulled a fingerprint from a bag containing guns and ammunition that matched Baines’s fingerprints. At trial, the prosecution (plaintiff) sought to introduce the fingerprint into evidence. Baines argued that the process of matching a latent fingerprint to a known fingerprint was unreliable and requested a Daubert hearing on the issue. The district court granted the motion. At the hearing, the prosecution called an expert witness to describe the process of matching fingerprints. The witness estimated that the Federal Bureau of Investigation’s error rate on fingerprint identification was about one in 11 million. The prosecution also called a witness from the forensic laboratory that conducted the matching in this case. Baines argued under Daubert that fingerprint identification was improperly subjective. Baines also argued that the process had not been sufficiently tested or peer reviewed. Further, Baines argued that the verification process, by which a second analyst reviewed the potential match, was not truly independent because the reviewer received the initial analyst’s notes and usually worked for the same entity. Finally, Baines argued that the process was not generally accepted in the scientific community. The district court ruled that the process was reliable and admitted the fingerprint evidence. Baines appealed.