State v. Chapple
135 Ariz. 281, 660 P.2d 1208 (1983)
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Rule of Law:
Expert testimony on the reliability of eyewitness identification may be admissible if it will assist the trier of fact in understanding the evidence or determining a fact in issue, particularly where identification is the sole contested issue and the testimony involves scientific principles beyond the jury's common knowledge.
Facts:
- Mel Coley, a drug dealer, arranged through a middleman, Malcolm Scott, to purchase 300 pounds of marijuana from another dealer, Bill Varnes.
- Coley arrived in Phoenix with two associates introduced as "Dee" and "Eric" with a plan to steal the marijuana rather than pay for it.
- At a trailer in Higley, Arizona, Scott and his sister, Pamela Buck, observed Coley, "Dee," and "Eric" cleaning guns and discussing the impending "rip-off."
- Varnes arrived at the trailer with two companions, Eduardo Ortiz and Carlos Elsy, to deliver the marijuana.
- After the marijuana was unloaded, Varnes and Ortiz were shot and killed inside the trailer, while Elsy was killed outside by a blow to the head.
- The assailants stole the marijuana, loaded the three bodies into Varnes's car, drove it into the desert, and set it on fire.
- The only evidence linking Dolan Chappie to the crime was the eyewitness identification made by Malcolm Scott and Pamela Buck from a photographic lineup more than a year after the murders, in which they identified Chappie as "Dee."
- Prior to identifying Chappie, Scott had failed to identify Chappie in an earlier photo array and had tentatively identified a photo of another man, James Logan, as resembling "Dee."
Procedural Posture:
- Dolan Chappie was charged in an Arizona trial court with three counts of first-degree murder, unlawfully transporting marijuana, and conspiracy.
- At trial, the court granted the State's motion in limine to preclude the defendant's expert witness from testifying about the reliability of eyewitness identification.
- The trial court admitted several gruesome photographs of a victim's body over the defendant's objection that they were inflammatory.
- A jury found Dolan Chappie guilty on all counts.
- Chappie was sentenced to concurrent life sentences for the murders and lengthy terms for the other counts.
- Dolan Chappie (defendant-appellant) appealed his judgment and sentence directly to the Supreme Court of Arizona.
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Issue:
Did the trial court abuse its discretion by precluding expert testimony on the psychological factors affecting the reliability of eyewitness identification where the defendant's guilt or innocence hinged entirely on the accuracy of that identification?
Opinions:
Majority - Feldman, Justice.
Yes. The trial court abused its discretion by precluding the expert testimony on eyewitness identification. Such testimony is admissible when it concerns specialized knowledge that will assist the trier of fact to understand variables affecting memory and perception that are beyond common experience. Here, identification was the sole contested issue, hinging on eyewitness accounts made long after the event. The expert's testimony on subjects like the 'forgetting curve,' the effect of stress on perception, unconscious transference, and the lack of correlation between witness confidence and accuracy was a proper subject under Rule 702 because it would have provided the jury with a scientific framework to evaluate the identification evidence, a task they could not perform as intelligently without it. The court also held that admitting gruesome and inflammatory photographs of the victim's charred body was an error because their probative value was substantially outweighed by the danger of unfair prejudice, as the facts they were offered to prove (cause of death) were not in dispute.
Concurring-in-part-and-dissenting-in-part - Hays, Justice,
No. The trial court did not abuse its discretion by excluding the expert testimony. The credibility of a witness is a matter for the jury to determine, and allowing expert testimony on the reliability of eyewitness identification invades the province of the jury. Weaknesses in an identification, such as time delay or stress, can be adequately explored through cross-examination and highlighted in closing arguments. Admitting such expert testimony risks allowing academia to take over the jury's fact-finding function and opens the door to experts testifying about any number of a witness's mental faculties, creating a 'deluge' of similar issues in future cases. The average juror is capable of understanding concepts like memory fading over time without expert guidance.
Analysis:
This decision marked a significant departure from the near-uniform judicial practice of excluding expert testimony on eyewitness identification. By recognizing that scientific research on memory and perception involves principles beyond the common knowledge of jurors, the court established a precedent for its admissibility in specific cases where identification is the crucial, disputed issue. This case paved the way for defendants to present a more scientifically grounded defense challenging the reliability of eyewitness accounts, influencing other jurisdictions to reconsider their blanket prohibitions. It underscores a judicial shift towards accepting the relevance of psychological science in the courtroom to aid the jury's fact-finding process.
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