State v. Young
35 So. 3d 1042 (2010)
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Rule of Law:
Expert testimony regarding the general reliability of eyewitness identification is inadmissible because its potential prejudicial effect on the jury outweighs its probative value, and it invades the province of the jury to determine witness credibility.
Facts:
- On September 8, 2006, Aaron Arnold and Dionne Grayson were in a restaurant parking lot when a man exited a white car, brandished a handgun, and demanded their wallets.
- Before they could comply, the gunman shot both Arnold and Grayson. Arnold died from his injuries.
- Nancy Segura witnessed the attempted robbery and shootings from a nearby vehicle but was not seen by the assailants.
- Information from a confidential informant led police to Sanchez Brumfield, who in turn implicated his cousin, Tracey Young, as the gunman.
- Dionne Grayson, the surviving victim, identified Tracey Young as the gunman in a photographic lineup two weeks after the shooting.
- Nancy Segura, the eyewitness, also identified Tracey Young as the gunman from a separate photographic lineup.
- Tracey Young denies any involvement in the crime.
Procedural Posture:
- An East Baton Rouge grand jury indicted Tracey Young for first degree murder.
- In the district court (trial court), the defense gave notice of its intent to introduce expert testimony on the reliability of eyewitness identifications.
- After a hearing, the district court ruled that the defendant’s proffered expert would be permitted to testify at trial.
- The State of Louisiana sought review of the district court's ruling from the intermediate court of appeal.
- The court of appeal denied the State's writ application, upholding the district court's decision to allow the testimony.
- The State of Louisiana then petitioned for and was granted certiorari by the Supreme Court of Louisiana to review the correctness of the district court’s ruling.
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Issue:
Does a district court abuse its discretion by ruling that a defendant may introduce expert testimony on the general factors affecting the reliability of eyewitness identification?
Opinions:
Majority - Guidry, Justice
Yes. A district court abuses its discretion by permitting expert testimony on the reliability of eyewitness identification because such testimony does not assist the trier of fact and is more prejudicial than probative. Reaffirming its precedent in State v. Stucke, the court held there is a compelling concern that a persuasive expert testifying on generalities already within a juror’s common knowledge will unduly influence the jury. The court reasoned that such testimony invades the exclusive province of the jury to determine witness credibility. Furthermore, the court found that alleged deficiencies in eyewitness testimony can be adequately addressed through effective cross-examination and specific jury instructions, making expert testimony unnecessary and undesirable.
Concurring - Knoll, Justice
Yes. Justice Knoll agreed with the outcome but argued for a per se, bright-line rule of inadmissibility. He characterized the “field of eyewitness identification psychology” as “junk science” that can never satisfy the Daubert/Foret standard for evidentiary reliability. In his view, the field lacks a known error rate, reliable testing methods, and general acceptance in the scientific community, and therefore should be categorically barred from court proceedings.
Concurring - Johnson, Justice
Yes. Justice Johnson concurred in the judgment but disagreed with the majority’s creation of a near-complete bar on such testimony. He argued that the admissibility of eyewitness expert testimony should be decided on a case-by-case basis. In this specific case, the expert testimony was properly excluded because there were multiple eyewitnesses and other corroborating evidence. However, he posited that in a case relying solely on the testimony of a single, uncorroborated eyewitness, such expert testimony might be admissible and assist the jury.
Analysis:
This decision reaffirms Louisiana's long-standing position, established in State v. Stucke, to exclude expert testimony on the reliability of eyewitness identification, placing it in contrast with a trend in many other jurisdictions to permit such evidence. The court's reasoning emphasizes protecting the jury's traditional role as the sole arbiter of witness credibility, viewing this type of expert testimony as an unhelpful and prejudicial invasion of that function. The concurring opinions reveal a significant division within the court, with one justice advocating for an even stricter per se ban and another arguing for a more flexible, case-by-case analysis, suggesting the issue may be revisited if a future case presents a weaker evidentiary foundation, such as a single uncorroborated witness.
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