State v. Oxford

Detailed jury instructions can remedy an unintentional prosecutorial mistake, and expert testimony lacking verified scientific reliability can be excluded.

Defendant appeals judgment of conviction for two counts of first-degree sodomy. He argues that the trial court erred by admitting statements of his sexual fantasies as propensity evidence. The Court of Appeals states any error was harmless because jurors were instructed not to consider that evidence when deciding the sodomy counts. When potentially propensity evidence is admitted, a detailed jury instruction explaining what can or cannot be used can lead courts to presume the jury followed those instructions. In addition, the court upheld the exclusion of expert testimony. Expert testimony must be reliable and can examine and critique the methodology behind the scientific knowledge they present. If the expert testimony is unable to provide meaningful testimony against peer-reviewed studies, it weighs against the expert testimony's admissibility. Here, the expert lacked knowledge of the error rate, the algorithm, and supporting peer-reviewed liability. Therefore, the Court concluded no errors appeared in the record. Affirmed.