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United States v. Crisp
United States Court of Appeals for the Fourth Circuit
324 F.3d 261 (2003)
Patrick Leroy Crisp (defendant) was convicted for crimes involving an armed bank robbery. Crisp appealed, arguing that the government’s expert testimony regarding fingerprints and handwriting was inadmissible because the government failed to establish that the basic premises of them were scientifically tested. As to fingerprints, Crisp pointed to law-review articles noting the lack of scientific data on fingerprint analysis and the Department of Justice’s solicitation of fingerprint-validation studies in 2000. During trial, Brannan, the government’s fingerprint expert, testified that she was not aware of any study finding that no two persons share the same fingerprint. Brannan testified that there is no generally accepted standard regarding the number of points of identification required to make a positive identification and that different agencies require different degrees of correlation. Brannan also testified that all fingerprint analysts must take a consistent, uniform points-and-characteristics approach established through professional training, peer review, presentation of conflicting evidence, and double checking. Finally, Brannan testified that there is a negligible error rate in fingerprint identification. Thomas Currin, the government’s handwriting expert, testified that all handwriting documents are analyzed by an examiner whose analysis is then reviewed by another examiner. Currin cited several studies to support handwriting analysis, and he testified that handwriting experts use a consistent methodology worldwide. During Currin’s testimony, he pointed out several consistent unique elements between Crisp’s handwriting sample and a note used in the robbery.
Rule of Law
Holding and Reasoning (King, J.)
Dissent (Michael, J.)
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