Summary
The Louisiana Court of Appeal, First Circuit denied the State’s application for supervisory writs in a matter arising from the Twentieth Judicial District Court, West Feliciana Parish. Judge Edwards dissented, concluding that the district court abused its discretion by excluding expert testimony concerning electronic monitoring systems and that the State satisfied the requirements of Louisiana Code of Evidence article 702 and Daubert.
Topics
Practice areas
Questions Presented
- Whether the district court erred in denying the State's request to present expert testimony concerning electronic monitoring systems.
- Whether the State was entitled to supervisory relief from the district court's evidentiary ruling.
Holdings
- The court denied the State's application for supervisory writs.
Key quotations
“Thus, I find the State met its burden of showing Mr. Dennis could assist the trier of fact to understand evidence or determine a fact at issue and that his practices were the product of reliable principles and methods and based upon sufficient facts and data.” (unpaginated opinion)
Factual background
The proffered expert, Mr. Dennis, had worked extensively with electronic ankle monitoring for eleven years and had served as director of the Assured Supervision Accountability Program since 2014. His company used electronic monitoring to track individuals' compliance with court orders or bond conditions and monitored approximately 400 offenders at a time. According to the dissent, Dennis testified about his company's standards and methodology based on his experience and knowledge.
Procedural history
The matter arose from the 20th Judicial District Court for the Parish of West Feliciana, case number 22-WFLN-237. The Louisiana Court of Appeal, First Circuit denied the State's supervisory-writ application. Judge Edwards dissented and would have granted the writ and reversed the district court's evidentiary ruling.