Criminal Law : Fingerprint Expert – Predicate Offense – Life Without Parole

Stephanie Maniscalco//July 4, 2018//

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(1)Where a defendant testified that fingerprint evidence in a methamphetamine case did not satisfy the Daubert test, analysis of admission under Daubert was not required since the defendant failed to show that the alleged erroneous admission affected his substantial rights at trial, so the district court did not err in failing to exclude the testimony.

(2)Where a defendant challenged the admission of a South Dakota drug offense as a predicate offense, the state conviction met the statutory requirements as a prior felony drug offense, and the defendant’s mandatory life sentence without parole did not violate the 8^th Amendment.

Judgment is affirmed.

U.S. v. Sorensen (MLW No. 71777/Case No. 17-1984 – 10 pages) (U.S. Court of Appeals, 8^th Circuit, Beam, J.) Appealed from U.S. District Court, District of South Dakota. (Paul C. Engh, Minneapolis, argued for appellant) (Jennifer D. Mammenga, Sioux Falls, South Dakota, argued for appellee).

Read the full text of this opinion. (PDF)