Motion to Invalidate Warrant and Suppress Evidence due to Insufficient Probable Cause Grounded in Unreliable Flock Data
This motion seeks to invalidate a warrant and suppress all resulting evidence where the warrant rests solely on Flock data. It explains that Flock’s machine-learning model generates conclusions based on a non-public AI model with an unknown error rate, is vulnerable to hallucinations, and is highly sensitive to weather, lighting, noise, and partial plate captures, […]
Motion for Attorney Conducted Voir Dire on Issue of Racial Bias
Incorporates studies on implicit bias generally, as well as specifically within jury panels
Request for Jury to Watch Video About Implicit Bias
Advocates that showing prospective jurors a video about implicit bias will help ensure a fair and impartial jury.
Motion to Exclude DNA “Likelihood Ratio” Testimony
Argues that “likelihood ratio” evidence — the statistical frequency of a suspect’s characteristic — has not been sufficiently validated and is misleading to the jury because the jury conflates it with probability of guilt.
Motion to Preclude Term “Felon” in a possession of a firearm case
p. 9-13 cite research on jury bias, impact of prior conviction evidence, and inefficacy of limiting instructions about prior convictions
Brief – Use of Term “Felon” and Introduction of Prior Convictions are Unfairly Prejudicial and should be Precluded
p. 8 – 12 outline existing research on how jurors respond to and use evidence of prior convictions. Incorporates research demonstrating that limiting instructions do not cure the prejudice, as jurors still use prior convictions as propensity evidence even when instructed not to.