United States v. I. Lewis Libby

429 F. Supp. 2d 27 (2006)

From our private database of 45,900+ case briefs, written and edited by humans—never with AI.

United States v. I. Lewis Libby

United States District Court for the District of Columbia
429 F. Supp. 2d 27 (2006)

Facts

During an investigation into who leaked classified information to journalists, exposing the name of Valerie Plame Wilson as an agent of the Central Intelligence Agency, I. Lewis Libby (defendant) was charged with obstruction of justice, making false statements, and perjury. Libby’s charges stemmed from comments he made to special agents of the Federal Bureau of Investigation (FBI) in October and November 2003 and to a grand jury in March 2004 that were allegedly false. Libby’s alleged false statements related to his recollection of statements he had made to FBI agents and a grand jury in June and July 2003 and conversations he had with various journalists. Libby pursued a faulty-memory defense and planned to argue that the state’s witnesses failed to correctly recall relevant details and that any mistakes he made were unintentional. Libby moved to introduce the expert testimony of Dr. Robert A. Bjork, who would testify that given how memory works, either the prosecution’s witnesses, Libby, or both could have simply remembered the subject conversations incorrectly. Federal Rule of Evidence 702 (Rule 702) governed the admissibility of expert testimony. In Daubert, the United States Supreme Court established a test for determining the admissibility of expert testimony under Rule 702. Expert testimony was admissible if the principles and methods on which the expert’s testimony was based (1) were scientifically reliable and (2) applicable to the facts at issue in the case and, therefore, of assistance to the fact-finder. The state did not object to Bjork’s testimony based on the first prong of the Daubert test, because science relating to memory was well established and had gained acceptance within the scientific community. However, the state argued that Bjork’s testimony would not aid the jury in understanding key issues in the case. Bjork was relying on studies showing that juries were often unaware of how fallible memory could be, but the studies were in relation to issues affecting the reliability of identifications of alleged perpetrators of crime made by eyewitnesses. The United States District Court for the District of Columbia did not believe that research related to the issues affecting the reliability of eyewitness identifications of alleged perpetrators of crime was applicable to issues affecting memory in other contexts. The typical juror was not often confronted, if ever, with having to identify an alleged criminal. However, a typical juror was faced daily with issues relating to memory and recalling information.

Rule of Law

Issue

Holding and Reasoning (Walton, J.)

What to do next…

  1. Unlock this case brief with a free (no-commitment) trial membership of Quimbee.

    You’ll be in good company: Quimbee is one of the most widely used and trusted sites for law students, serving more than 742,000 law students since 2011. Some law schools—such as Yale, Berkeley, and Northwestern—even subscribe directly to Quimbee for all their law students.

    Unlock this case briefRead our student testimonials
  2. Learn more about Quimbee’s unique (and proven) approach to achieving great grades at law school.

    Quimbee is a company hell-bent on one thing: helping you get an “A” in every course you take in law school, so you can graduate at the top of your class and get a high-paying law job. We’re not just a study aid for law students; we’re the study aid for law students.

    Learn about our approachRead more about Quimbee

Here's why 742,000 law students have relied on our case briefs:

  • Written by law professors and practitioners, not other law students. 45,900 briefs, keyed to 984 casebooks. Top-notch customer support.
  • The right amount of information, includes the facts, issues, rule of law, holding and reasoning, and any concurrences and dissents.
  • Access in your classes, works on your mobile and tablet. Massive library of related video lessons and high quality multiple-choice questions.
  • Easy to use, uniform format for every case brief. Written in plain English, not in legalese. Our briefs summarize and simplify; they don’t just repeat the court’s language.

Access this case brief for FREE

With a 7-day free trial membership
Here's why 742,000 law students have relied on our case briefs:
  • Reliable - written by law professors and practitioners, not other law students
  • The right length and amount of information - includes the facts, issue, rule of law, holding and reasoning, and any concurrences and dissents
  • Access in your class - works on your mobile and tablet
  • 45,900 briefs - keyed to 984 casebooks
  • Uniform format for every case brief
  • Written in plain English - not in legalese and not just repeating the court's language
  • Massive library of related video lessons - and practice questions
  • Top-notch customer support

Access this case brief for FREE

With a 7-day free trial membership