United States v. Morgan
- Court
- Court of Appeals for the D.C. Circuit (Federal circuit court)
- Decided
- 2022
- Citation
- 45 F.4th 192 (D.C. Cir. 2022)
- Standard applied
- FRE 702 — expert testimony on approximate cell-phone locations
What the court held
The D.C. Circuit rejected the argument that the district court abused its discretion by admitting government expert testimony about the approximate locations of the defendant's and a transported minor's cell phones on the relevant night, and affirmed the convictions.
Why
The court reviewed the admission of the location testimony for abuse of discretion and was unpersuaded that the district court had exceeded the latitude Rule 702 gives it, considering the challenge alongside the defendant's statutory and constitutional arguments and rejecting all three.
Our reading — not the court’s words
Why this matters in practice
Morgan belongs in the repository as the ordinary outcome that the reported exclusions can obscure: in most cases, carefully bounded cell-site location testimony is admitted. Read with Evans, the pattern is that opinions framed as approximate location survive while opinions framed as pinpoint location, or built on an assumption that the nearest tower was used, do not. The practical drafting lesson for an examiner is to state the uncertainty in the opinion rather than leave it to cross-examination.
This paragraph is Legal Cyber Academy’s editorial assessment of the decision’s practical importance. The court said none of it. For what the court actually said, read the opinion.
Additional detail
Tags: cell-site analysis · approximate location · abuse of discretion
Cited 24times in CourtListener’s corpus at the time this entry was compiled. Treat it as a rough measure of influence, not of correctness.
Other decisions on expert admissibility
- Daubert v. Merrell Dow Pharmaceuticals, Inc.Supreme Court of the United States · 1993The Court held that Frye's "general acceptance" test did not survive the Federal Rules of Evidence and is not a precondition to admitting scientific expert test…
- Kumho Tire Co. v. CarmichaelSupreme Court of the United States · 1999The trial judge's gatekeeping obligation under Rule 702 is not confined to “scientific” testimony; it applies to all expert testimony, including testimony resti…
- General Electric Co. v. JoinerSupreme Court of the United States · 1997A decision to admit or exclude expert testimony is reviewed for abuse of discretion, not under any more stringent standard because the ruling is outcome-determi…
- Frye v. United StatesCourt of Appeals for the D.C. Circuit · 1923Expert testimony deduced from a scientific principle is admissible only where the principle from which the deduction is made has gained general acceptance in th…
- United States v. UlbrichtCourt of Appeals for the Second Circuit · 2017The Second Circuit affirmed the exclusion of both of the defendant's proposed expert witnesses in the Silk Road prosecution because his expert notices were unti…
- Lorraine v. Markel American Insurance Co.District Court, D. Maryland · 2007Neither party's electronic exhibits could be considered because none was authenticated: e-mails were simply attached to the motions rather than supported by aff…
Summarised from the opinion as retrieved from CourtListener. Reference material, not legal advice. Back to the repository.