U.S. v. Holguin

It is within the court's "broad latitude" to deny a Daubert hearing. Kumho Tire Co. v. Carmichael, 526 U.S. 137, 142 (1999).

Prior to trial, Petitioners requested a Daubert hearing regarding the government’s expert witnesses but the district court denied the Petitioners’ request. After being convicted for conspiracy under the RICO Act, Petitioners appeal to the Ninth Circuit Court of Appeals raising a variety of claims as to the government’s use of expert witnesses at trial. These claims include that the district court erred in denying the request for a Daubert hearing, that it abused discretion in making no reliable findings and it erred by allowing dual-role testimony. It is within the court's "broad latitude" to deny a Daubert hearing. Kumho Tire Co. v. Carmichael, 526 U.S. 137, 142 (1999).The Court determined that the district court did not err or abuse its discretion in allowing expert testimony at trial. The Court reasoned that the district court had authority to deny a Daubert hearing as it is not required and although the district court did not make reliable findings, it was a harmless error because the record supports the reliability of expert testimony. The Court further reasoned that the district court did not err in allowing dual-role testimony as the district court had implemented safeguards to decrease the dangers that dual-role testimony can cause. Therefore, the Court held that the district court did not err in regard to expert testimony at trial and affirmed Petitioners’ convictions. AFFIRMED.