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State v. Chapple

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Brief Fact Summary. The defendant, Dolan Chapple (the “defendant”), was convicted of three counts of murder primarily based on an eye witness identification. The defendant claimed he was out of state at the time of the murders, and witnesses testified in his support. He offered an expert on eye witness testimony during trial to support his claim of mistaken identify, but the trial court did not allow the expert testimony.

Synopsis of Rule of Law. Expert testimony may be admitted if the scientific, technical, or other specialized knowledge will assist the trier of fact in understanding evidence or determining a fact in issue.

Points of Law - Legal Principles in this Case for Law Students.

Photographs may be relevant to prove the corpus delicti, to identify the victim, to show the nature and location of the fatal injury, to help determine the degree or atrociousness of the crime, to corroborate state witnesses, to illustrate or explain testimony, and to corroborate the state's theory of how and why the homicide was committed.

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Facts. The defendant was convicted of three counts of murder. Mel Coley (“Mr. Coley”), a drug dealer in Washington D.C., had a history of dealing with a supplier named Bill Varnes (“Mr. Varnes”) who lived near Phoenix. Mr. Coley made a large number of drug deals with Malcolm Scott (“Mr. Scott”) who also lived near Phoenix. Mr. Scott met Mr. Coley for an arranged drug deal in Washington, D.C. Mr. Scott was accompanied by two individuals known as “Dee” and “Eric.” Mr. Scott’s sister, Pamela Buck (“Ms. Buck”), also helped arrange the drug deal. The defendant is accused of being “Dee”, which he denies. Mr. Scott drove Mr. Coley, Eric and Dee to a trailer which was the meeting place. Mr. Varnes, Eduardo Ortiz (“Mr. Ortiz”), and Carlos Elsy (“Mr. Elsy”), delivered the marijuana to the trailer. After they were finished unloading, Dee suggested to Mr. Varnes that they go to the bedroom to count the money. Shortly thereafter, shots were fired. Mr. Varnes and Mr. Ortiz were shot and
killed with different weapons, and Mr. Elsy was killed by a blow to the back of the head. Mr. Scott, Eric and Dee loaded the bodies into the truck of Mr. Varnes’ car. They drove the car out to the desert and set it on fire. Mr. Scott would eventually hire a lawyer and negotiate an immunity deal in return for his surrender.
During his extradition hearing in Illinois, seven witnesses place the defendant in Cairo, Illinois during the entire month of December 1977. Three testified that he was in that town on the day of the murders. The witnesses also testified on his behalf during the trial. The testimony of Mr. Scott and Ms. Buck is the only evidence connecting the defendant to the crime. Mr. Scott and Ms. Buck did not know the defendant, but picked his photograph out of a lineup more than a year after the crime. The defendant argued that the identification is a case of mistaken identity, and offered expert testimony regarding the reliability of identification evidence. The trial court rejected the testimony because it is not within the proper sphere of expert testimony.

Issue. Did the trial court abuse its discretion in not allowing the testimony of the defendant’s expert on eyewitness identification?

Held. Justice Feldman issued the opinion for the Supreme Court of Arizona, holding that the trial court did abuse its discretion in not allowing the expert testimony.

Dissent. Justice Hays dissents because he believes the Court has “opened the door” to testimony attacking other supposed or real deficiencies regarding mental abilities. He believed the ruling disturbs the fact-finding role of the jury.

Discussion. Four criteria should be applied in order to determine the admissibility of an expert on eyewitness testimony: 1) qualified expert; 2) proper subject; 3) conforms to a generally accepted explanatory theory; and 4) probative value compared to prejudicial effect. The State conceded that the defendant’s expert met the first and third criteria, thus the Supreme Court of Arizona only examined the proper subject and probative value issues criteria. The opinion notes that the expert’s testimony in this case was beyond the knowledge of the average juror and would assist the jury in determining the issues before them. Proper identification was the most important issue in the case, and the opinion illustrates that based on the facts in the case, the testimony might have assisted the jury in resolving some of the fact issue without being unfairly prejudice to the prosecution.

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