State of Alaska, Petitioner and Cross-Respondent v. Jyzyk J. Sharpe, Respondent and Cross-Petitioner. State Of…

Summary

The Alaska Supreme Court adopted a hybrid standard for reviewing scientific-evidence rulings: preliminary factual findings receive clear-error review, scientific validity is reviewed independently, and case-specific admissibility decisions receive abuse-of-discretion review. Applying that standard, the court held that comparison-question-technique polygraph evidence had not been shown sufficiently reliable under the governing scientific-evidence standard and therefore could not be admitted over objection. The court reversed the rulings admitting the evidence in Alexander and Sharpe, affirmed the exclusion in Holt, and remanded each matter for further proceedings.