📄 Sidebar: NRC report reliance — Thursday, May 11, 1995
📅 May 11 — Day 72
⚖️ Lance A. Ito🛡️ Peter Neufeld
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TRIAL
▲ Day 72 of 167

Sidebar: NRC report reliance

Date: Thursday, May 11, 1995 • Utterances: 12
At sidebar, defense attorney Peter Neufeld argues he should be allowed to cross-examine an expert witness using the National Research Council's DNA report, contending that California law only requires the witness 'considered' the report, not that she formally 'relied' on it. Prosecutor George Clarke counters that case law under Evidence Code section 721 requires actual reliance for the report to avoid being classified as hearsay. Judge Ito sustains the objection, affirming that California law requires the witness to have relied upon the material in forming her opinion.
1 (The following proceedings were held at the bench:)
2 THE COURT:

All right. We are over at sidebar. Mr. Neufeld.

3 MR. NEUFELD:

My understanding--I am not a California lawyer, your Honor--is that it's not necessary that I demonstrate she relied on this treatise at all. It is sufficient to show that she either referred to it, considered or relied upon it, upon such publication at arriving at her opinions. So I thought that my initial questions--

4 THE COURT:

Keep your voice down, counsel.

5 MR. NEUFELD:

My questions when she answered initially on the issue of considered was adequate foundation. I didn't think I had to ask her whether she relied on it. In fact, it's sufficient even if she rejected large portions of it. The fact--one thing that's interesting here, your Honor, on direct examination, it was brought out by Mr. Clarke that she's read this thing many, many, many times herself. That was her testimony. Clearly if she's read it many, many, many times, she did consider it in arriving at opinions and decided those things. She's attempting--and which she remembers. And what bothers me now is that there's no question that this is the primary treatise by government agencies on this subject right now.

6 THE COURT:

Used to be.

7 MR. NEUFELD:

Well. You're saying used to be because there's not been an NRC committee meeting. But the scientific community hasn't even reached a conclusion yet, hasn't written a report. To the extent that she wants to say she doesn't agree with it, I have no problem with it. But to allow this witness to avoid cross-examination on the NRC report frankly is preventing the jury from hearing all the facts that are of concern to them, especially in light of your Honor's--especially in light of the fact that this witness said that she read this report many times on direct examination, which she said on cross-examination she read it and she's considered it in reaching her understanding of these various subjects, although--

8 THE COURT:

I don't think that's quite what she said. Mr. Clarke.

9 MR. CLARKE:

Yes. My memory having been refreshed--and I'm not sure Mr. Neufeld was present--is, this very issue was litigated by this Court previously by formal motion. And evidence code 720, section 721 says counsel must rely--case law has made it clear the witness must have relied upon it for purposes of formation of the opinion. So she may have read it a hundred times. I may have read a book about being a lawyer a hundred times. That doesn't mean that it's something I rely upon, or as the case is here, the witness relies upon it in rendering an opinion. And until that foundation is present, the case law clearly calls this type of material hearsay.

10 THE COURT:

All right. The objection at this point is sustained.

11 MR. NEUFELD:

Your Honor, just for guidance--

12 THE COURT:

California law says they have to have relied upon this in forming their opinion. That's what it says.

KEY QUOTE

Temperature

procedural

Key Quotes (4)

Peter Neufeld
it's not necessary that I demonstrate she relied on this treatise at all. It is sufficient to show that she either referred to it, considered or relied upon it, upon such publication at arriving at her opinions.
Neufeld's core legal argument — he's trying to apply a lower threshold than California law actually requires.
Lance A. Ito
Used to be.
Ito punctures Neufeld's characterization of the NRC report as the current primary government treatise on DNA — a one-word correction that signals skepticism toward Neufeld's framing.
George Clarke
She may have read it a hundred times. I may have read a book about being a lawyer a hundred times. That doesn't mean that it's something I rely upon.
Clarke's sharp analogy dismantles the 'read many times = considered = relied upon' chain of reasoning Neufeld is trying to establish.
Lance A. Ito
California law says they have to have relied upon this in forming their opinion. That's what it says.
Ito's definitive ruling, closing off further argument and affirming Clarke's position on the evidentiary standard.

Evidence (1)

Informal
National Research Council (NRC) report on DNA evidence — the primary government treatise on forensic DNA at the time
disputed as foundation for cross-examination of expert witness

Notable Exchanges (2)

Peter NeufeldLance A. Ito
Neufeld argues the NRC report is 'the primary treatise by government agencies on this subject right now'; Ito flatly replies 'Used to be,' undercutting Neufeld's premise before he can build on it.
strategic
George ClarkePeter Neufeld
Clarke reframes the dispute around Evidence Code 721 and prior motion practice on this exact issue, arguing the reliance standard is settled law the court has already ruled on.
procedural

Objections

1 objections (1 sustained, 0 overruled)
Proceeding 6036 • 12 utterances
Criminal Trial
Department 103
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📂 MAY 11, 1995 📄 Sidebar: NRC report reliance
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