State v. Sharpe

Summary

The court replaced abuse-of-discretion review for the scientific-validity component of expert-evidence rulings with a hybrid standard: factual findings receive clear-error review, scientific validity receives independent appellate review, 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 ruling in Holt, and remanded each case for further proceedings as specified.