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United States v. Bonds

922 F.3d 343 (2019)

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United States v. Bonds

United States Court of Appeals for the Seventh Circuit
922 F.3d 343 (2019)

JC

Facts

Myshawn Bonds (defendant) was convicted of bank robbery and sentenced to five years in prison. The government (plaintiff) introduced evidence at trial that included the testimony of Federal Bureau of Investigation forensic examiner Kira Glass. Glass testified that using the analysis, comparison, evaluation, and verification (ACE-V) method, prints on demand notes from the bank robberies in question matched fingerprints from Bonds. At issue was the reliability of the ACE-V method, which had produced error rates in studies ranging from 1 in 18 to 1 in 604, but the court found the method sufficient to withstand scrutiny under Federal Rule of Evidence 702. Additionally, Glass had worked at a laboratory that had previously erred in identifying Brandon Mayfield as connected with a terrorist bombing in Spain. Bonds wanted to discuss the Mayfield case in depth at trial to demonstrate the possibility of error. Although the trial judge allowed Bonds to discuss the concerns about the reliability of the ACE-V method and some potential error-causing issues previously raised by the President’s Council of Advisors on Science and Technology, the court did not allow discussion of the Mayfield case. Bonds appealed his conviction, alleging that failure to allow Mayfield to be discussed was error.

Rule of Law

Issue

Holding and Reasoning (Easterbrook, J.)

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