Motion To Compel Discovery Pursuant to Maryland Rule 4-262 Concerning Operation and Reliability of Flock Data
This motion argues that Flock’s ALPR and Vehicle Fingerprint® systems are secretive, unregulated, and error-prone artificial intelligence tools whose reliability cannot be assessed without robust discovery into how they function, how they were developed and trained, and what their error rates are (pp. 4-7). It explains that machine-learning “hallucinations,” environmental conditions (weather, lighting, camera noise), […]
Motion to Exclude Child Sexual Abuse Accommodation Syndrome (CSAAS) Testimony
This motion challenges a forensic child abuse investigator’s attempt to bolster a child complainant’s credibility in a sexual assault case through testimony about Child Sexual Abuse Accommodation Syndrome (CSAAS). Drawing on social science and precedent, the motion argues that CSAAS testimony is not admissible under FRE 702 & Daubert because it is not scientifically reliable […]
Amicus Brief Arguing that Internet Searches About Abortion and Lack of Prenatal Care Are Not Relevant Evidence of Murderous Intent Toward Newborn
This amicus brief argues that the State and lower courts relied upon irrelevant, unfairly prejudicial evidence (i.e. internet search history regarding abortion, abstention from prenatal care) to “articulate a motive for a murderous act on a newborn child.” The brief discusses the unfair prejudice that flows from admission of this evidence given stereotypes about women […]
Motion to Exclude Testimony – Forensic Fingerprint Examiner
Explains history of the ACE-V method, the risk of confirmation bias, and the lack of uniform standards in fingerprint matching.