Indiana Evidence

Daubert replaced the longstanding Frye 'general acceptance' test with a more flexible, multi-factor framework for determining the admissibility of expert scientific testimony under Federal Rule of Evidence 702. The decision assigned trial judges a gatekeeping role to ensure that expert testimony is both relevant and reliable. It fundamentally reshaped the landscape of scientific evidence in federal courts.

Frye established the 'general acceptance' test for the admissibility of scientific evidence, which dominated American evidence law for seventy years. The standard required that a scientific technique be generally accepted in the relevant scientific community before it could be admitted as evidence. Although superseded in federal courts by Daubert, the Frye test remains the standard in several states.

Crawford revolutionized Confrontation Clause jurisprudence by holding that the Sixth Amendment bars the admission of testimonial hearsay unless the declarant is unavailable and the defendant had a prior opportunity to cross-examine. The decision overruled Ohio v. Roberts and its reliability-based framework, returning to the original meaning of the Confrontation Clause as understood by the Framers.

Davis clarified Crawford's testimonial framework by establishing the 'primary purpose' test for distinguishing testimonial from nontestimonial statements made during police interrogations. The decision held that statements are nontestimonial when made during an ongoing emergency and become testimonial when the primary purpose shifts to establishing facts for later criminal prosecution.

Ohio v. Roberts established a two-part test for the Confrontation Clause that governed for nearly a quarter century: an out-of-court statement was admissible if the declarant was unavailable and the statement bore adequate 'indicia of reliability,' either by falling within a firmly rooted hearsay exception or showing particularized guarantees of trustworthiness. Although overruled by Crawford, Roberts remains important for understanding the evolution of confrontation law.

Bruton established that in a joint trial, the admission of a non-testifying co-defendant's confession that implicates the defendant violates the defendant's Sixth Amendment right to confrontation, even when the jury is instructed to consider the confession only against the co-defendant. The decision recognized the practical limits of limiting instructions in the face of powerfully incriminating evidence.

Hillmon established the 'state of mind' exception to the hearsay rule, holding that a declarant's statements of intent or plan are admissible to prove that the declarant subsequently acted in accordance with that stated intention. This principle was later codified in Federal Rule of Evidence 803(3) and remains one of the most important and frequently tested hearsay exceptions.

Tome resolved a circuit split on the temporal requirement for prior consistent statements under Federal Rule of Evidence 801(d)(1)(B). The Court held that a prior consistent statement is admissible to rebut a charge of recent fabrication or improper motive only if the statement was made before the alleged motive to fabricate arose, thereby preserving the pre-Rules common law premotive requirement.

Old Chief addressed the application of Federal Rule of Evidence 403 when a defendant offers to stipulate to a prior conviction that is an element of the charged offense. The Court held that where the risk of unfair prejudice from the name and nature of a prior conviction substantially outweighs its probative value, and the defendant offers to stipulate to the fact of a prior conviction, the trial court abuses its discretion by refusing the stipulation. The case is a landmark on the Rule 403 balancing test.

Huddleston resolved the standard of proof required before a trial court may admit evidence of other crimes, wrongs, or acts under Federal Rule of Evidence 404(b). The Court held that such evidence need not be proven by a preponderance of the evidence or clear and convincing evidence; rather, the trial court need only determine that a jury could reasonably find the conditional fact by a preponderance of the evidence under the Rule 104(b) standard.