State v. Edwards, 2017 WL 1194851 (Conn. 2017)
Edwards was convicted of a home invasion robbery. He followed a woman home from a grocery store, entering her garage and brandishing a gun. In addition to Edwards’ fingerprints on the side of the victim’s car, the victim’s identification of Edwards’ car (but not Edwards), surveillance video and other evidence, the prosecution elicited testimony from a police detective regarding cell site location information (CSLI) for Edwards’ phone.
The Connecticut Supreme Court held that the trial court improperly allowed the officer to testify about the CSLI evidence from Edwards’ phone without establishing the officer as an expert witness.
On appeal, Edwards challenged the admission of the CSLI, asserting the trial court improperly admitted the CSLI evidence without determining that the evidence was based on reliable scientific principles, as required by the Supreme Court in Daubert v. Merrell Dow Pharmaceuticals, Inc. (509 U.S. 579 (1993)). Daubert requires trial courts to determine that the scientific methods used to reach a particular conclusion are reliable and that the evidence is relevant.
The Connecticut Supreme Court held that the trial court improperly allowed the officer to testify about the CSLI evidence from Edwards’ phone without establishing the officer as an expert witness. This case signals officers to be prepared to explain the scientific method behind CSLI and to show that the evidence is scientifically sound before a court may properly admit it as evidence. It isn’t enough just to download the data; the officer must explain how the CSLI is collected.
Even though the Court found the cell phone evidence to be improperly admitted, there was adequate other evidence to sustain Edwards’ conviction.
Court: Officers Must Be Able to Demonstrate Knowledge of the Electronic Surveillance Devices They Use