Sturgeon, Richard Glen v. State

CourtCourt of Appeals of Texas
DecidedAugust 23, 2005
Docket14-04-00311-CR
StatusPublished

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Bluebook
Sturgeon, Richard Glen v. State, (Tex. Ct. App. 2005).

Opinion

Affirmed and Memorandum Opinion filed August 23, 2005

Affirmed and Memorandum Opinion filed August 23, 2005.

In The

Fourteenth Court of Appeals

____________

NO. 14-04-00311-CR

RICHARD GLEN STURGEON, Appellant

V.

THE STATE OF TEXAS, Appellee

_____________________________________________________

On Appeal from the 182nd District Court

Harris County, Texas

Trial Court Cause No. 812,784

M E M O R A N D U M   O P I N I O N

Appellant Richard Glen Sturgeon appeals from his conviction for aggravated robbery. In his sole point of error, appellant argues that the trial court erred when it excluded expert testimony on the reliability of eyewitness identifications.  We affirm.

Background


In the early hours of Christmas morning of 1998, two men robbed complainant Minh Nguy at gunpoint in his driveway, taking his wallet, keys, and car.  Later that day, police stopped appellant when they found him driving yet another stolen car.  Police officers found Nguy=s stolen personal items in the possession of one of the passengers in the car.  Realizing appellant matched the description of one of Nguy=s attackers, police detained him.  After Nguy identified appellant as one of the men who attacked him, appellant was charged with aggravated robbery.

At trial, the defense proffered the expert testimony of Dr. Steven Smith on the reliability of eyewitness identifications.  The trial court conducted a Kelly/Daubert[1] hearing out of the presence of the jury.  Dr. Smith has been a professor of cognitive psychology for the past twenty-three years.[2]  He has published over fifty articles on cognitive psychology in peer reviewed journals.  Dr. Smith testified that there were hundreds of studies and experiments addressing problems with eyewitness identification.  The studies suggest that factors such as lighting, duration of exposure, weapon focus, and cross-racial identification have been found to be factors affecting eyewitness identification.  However, Dr. Smith did not participate in any of the studies, could not name the researchers or institutions involved, and did not produce any articles regarding these studies to the court.  He produced six articles to the court, only one of which addressed eyewitness testimony.

Dr. Smith was unfamiliar with the facts of the case and had not interviewed anyone other than appellant.  When he did recite the facts as he knew them, he incorrectly described the robbery as involving three men dragging Nguy from a car when the facts show that two men approached Nguy while he was standing in his driveway.  He further testified that he did not intend to give an opinion as to the reliability of Nguy=s identification but felt his role was to educate the jury regarding developments in the study of memory.


After hearing Dr. Smith=s testimony, the court determined that it was neither reliable nor relevant.  While the court noted that the study of memory itself was an established science, Dr. Smith=s lack of background in the area of eyewitness testimony called his individual reliability on that subject into question.  Dr. Smith was not only unfamiliar with the actual facts of the case, but the few facts he recited were incorrect.  Since Dr. Smith=s testimony was not in any way tailored to the facts of the case, the court held that his testimony was not relevant.  Accordingly, the trial court ruled that Dr. Smith=s testimony was inadmissible.

Following a jury trial, appellant was convicted of aggravated robbery and sentenced to twenty-five years= imprisonment.  This appeal followed.

Analysis

Standard of Review

We review a judge=s decision on the admissibility of evidence under an abuse of discretion standard and will not reverse the court=s ruling if it is within the zone of reasonable disagreement.  Sexton v. State, 93 S.W.3d 96, 99 (Tex. Crim. App. 2002).  Rule 702 of the Texas Rules of Evidence states

If scientific, technical, or other specialized knowledge will assist the trier of fact to understand the evidence or to determine a fact in issue, a witness qualified as an expert by knowledge, skill, experience, training, or education may testify thereto in the form of an opinion or otherwise.

Tex. R. Evid. 702.  For testimony to be admissible under Rule 702, the party offering the testimony must demonstrate, by clear and convincing proof, that the testimony Ais sufficiently reliable and relevant to help the jury in reaching accurate results.@  Kelly v. State, 824 S.W.2d 568, 572 (Tex. Crim. App. 1992).


Reliability

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Related

Daubert v. Merrell Dow Pharmaceuticals, Inc.
509 U.S. 579 (Supreme Court, 1993)
Nenno v. State
970 S.W.2d 549 (Court of Criminal Appeals of Texas, 1998)
Russeau v. State
171 S.W.3d 871 (Court of Criminal Appeals of Texas, 2005)
Salazar v. State
127 S.W.3d 355 (Court of Appeals of Texas, 2004)
Sexton v. State
93 S.W.3d 96 (Court of Criminal Appeals of Texas, 2002)
Weatherred v. State
15 S.W.3d 540 (Court of Criminal Appeals of Texas, 2000)
Jordan v. State
928 S.W.2d 550 (Court of Criminal Appeals of Texas, 1996)
Kelly v. State
824 S.W.2d 568 (Court of Criminal Appeals of Texas, 1992)
Williams v. State
895 S.W.2d 363 (Court of Criminal Appeals of Texas, 1994)

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Sturgeon, Richard Glen v. State, Counsel Stack Legal Research, https://law.counselstack.com/opinion/sturgeon-richard-glen-v-state-texapp-2005.