STATE OF NEW JERSEY VS. DAVID GHIGLIOTTY (17-02-0154, UNION COUNTY AND STATEWIDE)

CourtNew Jersey Superior Court Appellate Division
DecidedApril 20, 2020
DocketA-0938-19T3
StatusPublished

This text of STATE OF NEW JERSEY VS. DAVID GHIGLIOTTY (17-02-0154, UNION COUNTY AND STATEWIDE) (STATE OF NEW JERSEY VS. DAVID GHIGLIOTTY (17-02-0154, UNION COUNTY AND STATEWIDE)) is published on Counsel Stack Legal Research, covering New Jersey Superior Court Appellate Division primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
STATE OF NEW JERSEY VS. DAVID GHIGLIOTTY (17-02-0154, UNION COUNTY AND STATEWIDE), (N.J. Ct. App. 2020).

Opinion

NOT FOR PUBLICATION WITHOUT THE APPROVAL OF THE APPELLATE DIVISION

SUPERIOR COURT OF NEW JERSEY APPELLATE DIVISION DOCKET NO. A-0938-19T3

STATE OF NEW JERSEY,

Plaintiff-Appellant, APPROVED FOR PUBLICATION

v. April 20, 2020

APPELLATE DIVISION DAVID GHIGLIOTTY,

Defendant-Respondent. _________________________

Argued telephonically March 18, 2020 – Decided April 20, 2020

Before Judges Fuentes, Haas and Enright.

On appeal from an interlocutory order of the Superior Court of New Jersey, Law Division, Union County, Indictment No. 17-02-0154.

Michele C. Buckley, Special Deputy Attorney General/Acting Assistant Prosecutor, argued the cause for appellant (Lyndsay V. Ruotolo, Acting Union County Prosecutor, attorney; Michele C. Buckley, of counsel and on the brief).

Elizabeth Cheryl Jarit, Deputy Public Defender, argued the cause for respondent (Joseph E. Krakora, Public Defender, attorney; Elizabeth Cheryl Jarit, of counsel and on the brief).

The opinion of the court was delivered by HAAS, J.A.D.

In this appeal, we address the novel issue of whether a firearms toolmark

identification expert's use of untested three-dimensional (3D) computer

imaging technology known as BULLETTRAX, in conjunction with the

traditional technique of comparing evidence and test bullets using a

comparison microscope, requires that a Frye1 hearing be held to establish the

scientific reliability of the BULLETTRAX machine and related software.

Following an evidentiary hearing, the trial court concluded that the

State's expert relied upon the BULLETTRAX technology and the images it

produced in concluding that a bullet fragment taken from the murder victim

likely came from a handgun later seized from defendant David Ghigliotty. In

so ruling, the court made extensive factual and credibility findings pertaining

to the expert's testimony about his use of the images, and its findings are

entitled to our deference on appeal. Under these circumstances, we conclude

that the court correctly determined that a Frye hearing was necessary to

demonstrate the reliability of the computer images of the bullets produced by

BULLETTRAX before the expert would be permitted to testify at trial.

1 Frye v. United States, 293 F. 1013, 1014 (D.C. Cir. 1923).

A-0938-19T3 2 I.

To place this issue in its proper context,2 we begin by providing a

general overview of the field of firearm identification, which "is a specialized

sub-specialty of toolmark identification specifically related to the firearm

mechanism's working surfaces." Thompson at 7-8, 28. In this case, the "tool"

is the firearm. Thompson at 7; 2009 NRC Report at 150-51. The tool

surfaces, which include the interior of the firearm barrel, the chamber, and

parts of the action, "can produce toolmarks on fired and unfired ammunition

components." Thompson at 7. Toolmarks are "inherently three-dimensional."

2008 NRC Report at 186.

2 The necessary contextual background information pertaining to firearm and toolmark identification presented in this section is primarily taken from four scientific reports that defendant submitted to the trial court. Portions of the reports were also cited in the trial court's opinion.

The four reports, and the citations we will use to refer to them, are as follows: (1) Robert M. Thompson, Firearm Identification in the Forensic Science Laboratory (National District Attorneys Association, Alexandria, VA), 2010 (Thompson); (2) National Research Council, Committee to Assess the Feasibility, Accuracy, and Technical Capability of a National Ballistics Database, Ballistic Imaging (Nat'l Academies Press, Washington, D.C.), 2008 (2008 NRC Report); (3) National Research Council, Committee on Identifying the Needs of the Forensic Science Community, Strengthening Forensic Science in the United States: A Path Forward (Nat'l Academies Press, Washington, D.C.), 2009 (2009 NRC Report); and (4) President's Council of Advisors on Science and Technology, Report to the President, Forensic Science in Criminal Courts: Ensuring Scientific Validity of Feature-Comparison Methods (Executive Office of the President), September 2016 (PCAST Report).

A-0938-19T3 3 Toolmark evidence may consist of "class characteristics," which are not

unique, and "individual characteristics," which are "microscopically

dissimilar." Thompson at 8-10. "Class characteristics" are firearm features

"shared by many items of the same type" and determined by the manufacturer

that "help narrow the population of potential firearm sources" when doing an

identification. Thompson at 8; 2009 NRC Report at 152. They include "the

size of the cartridge chambered by the firearm, the orientation of the extractor

and ejector, and the number, width, and twist direction of the land and grooves

of the barrel rifling." Thompson at 8, 15; 2009 NRC Report at 152.

In contrast, "individual characteristics" of a firearm are "fine

microscopic markings and textures" that "are random in nature, usually arising

from the tool working surface incidental to manufacture, but can also be the

result of use, wear, and possible care and/or abuse of the tool," and that form

striated or impressed toolmarks on ammunition. Thompson at 9-11; 2009 NRC

Report at 152. Because of their uniqueness, a firearm's individual

characteristics make firearm identification possible, so long as the toolmarks

imparted are "reproducible for comparisons." Thompson at 7-9.

"For the science of toolmark identification, the underlying hypothesis is

that a toolmark can be identified to a specific tool that produced it, to the

practical exclusion of all other tools." Thompson at 9-10; 2009 NRC Report at

A-0938-19T3 4 150. Although it is impossible to prove the hypothesis "by testing all tools

ever produced in the world," firearms examiners make identifications "based

on observation and experimentation" which includes the consideration of

"known non-match" toolmark comparisons. Thompson at 10; 2009 NRC

Report at 152.

The science of firearm and toolmark identification is well-established,

spanning over 100 years in the United States. Thompson at 8. "There is a

foundation of knowledge about firearm and toolmark identification that has

been organized over time and is described in forensic textbooks, scientific

literature, reference material, training manuals, and peer reviewed scientific

journals." Thompson at 28-29. The Association of Firearm and Toolmark

Examiners (AFTE), an international body of practitioners, is the largest

professional organization in the field and publishes a professional journal

concerning firearm and toolmark science. Thompson at 11, 29.

Neither the underlying principles nor the methodology has changed

significantly during the last 100 years. Thompson at 8. The AFTE recognizes

that the "most widely accepted method used in conducting a toolmark

examination is a side-by-side, microscopic comparison of the markings on a

questioned material item to known source marks imparted by a tool." PCAST

Report 104. A firearms toolmark examiner uses a comparison microscope to

A-0938-19T3 5 compare toolmarks on an evidence bullet with toolmarks present on a test fired

bullet from the suspected weapon that is linked to either the crime scene or a

suspect. Thompson at 10, 27. Class characteristics are evaluated first,

followed by individual characteristics. Thompson at 26; 2009 NRC Report at

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STATE OF NEW JERSEY VS. DAVID GHIGLIOTTY (17-02-0154, UNION COUNTY AND STATEWIDE), Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-of-new-jersey-vs-david-ghigliotty-17-02-0154-union-county-and-njsuperctappdiv-2020.