Wednesday, December 4, 2013

United States v. Crumby case brief

United States v. Crumby case brief summary
895 F. Supp. 1354 (D. Ariz. 1995)

Defendant filed a motion for an evidentiary hearing as to the reliability and admissibility of polygraph evidence in his trial on charges of bank robbery and aid and abet.

Defendant, indicted for bank robbery and aid and abet in violation of 18 U.S.C.S. §§ 2113(a),2, submitted to a polygraph examination. The polygraph examiner evaluated the exam's results and determined that defendant passed the test. Defendant sought the admission of the polygraph evidence.

  • The court held that the polygraph evidence was admissible because the evidence was sufficiently reliable under the Daubert standard to be admitted as scientific evidence under Fed. R. Evid. 702. 
  • However, the court further ruled that defendant could introduce the evidence only for a limited purpose because the use of polygraph evidence at trial had to be narrowly tailored to the circumstances for which it was relevant and circumscribed so as to limit its potential prejudicial effects. 
  • It was thus admissible for the instant case subject to the preliminary requirements that the government was provided sufficient notice and a reasonable opportunity to administer a polygraph exam that was materially similar to the previously taken examination, and that the evidence was admissible only to impeach or corroborate the testimony of defendant.
The court granted in part and denied in part defendant's motion as to the admissibility of the polygraph examination.

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