Motion to Compel Discovery Related to Veracity of Presumptive Field Drug Tests
This motion seeks discovery concerning the reliability of colorimetric presumptive field drug tests, arguing that these tests are unreliable and prone to high false-positive rates. Drawing on empirical research and audits from jurisdictions nationwide, the motion explains that common legal substances frequently trigger positive results and that accuracy varies widely based on officer training, storage, and administration. It argues […]
Motion to Exclude Ballistics Expert Evidence
This brief follows an extensive Frye hearing on bullet matching evidence and incorporates extensive criticism from the scientific community, an explanation of the unintended impact that a narrow definition of the “relevant scientific community” can have, and evidence of the ways that cognitive bias impermissibly taint pattern-matching evidence.
Shotspotter – Civil Complaint – ShotSpotter Is Unreliable and Ineffective
p. 13-59 overview studies of Shotspotter accuracy and racially biased implementation
Amicus Brief – Bite mark comparison testimony is inherently unreliable
p. 35-65 detail research demonstrating bite-mark comparison has “no empirical support” high error rates, and is not accepted within the scientific community
Amicus Brief – Police Violence Increases Risk of False Confessions
p. 14 to 21 cites research on false confession risk factors and police techniques that increase risk
Motion to Bar Testimony – Shaken Baby Syndrome
Focusing on retinal hemorrhages, this motion cites research showing no proven correlation between shaking and retinal hemorrhage, as well as studies documenting other (non-shaking) causes of retinal hemorrhage.
Amicus Brief – Courts should exclude “criminal profiling” and non-scientific “crime scene analysis” evidence
Summarizes research on accuracy of “criminal profiling” evidence over forty years, concluding profilers are no “better than bartenders at predicting the traits and features of offenders.” Also provides an overview of cases nationwide excluding criminal profiling evidence and finding that its major premise is faulty and essentially propensity evidence.