Donaldson v. State
Michael Donaldson v. State of Mississippi, 262 So. 3d 1135 (2018). Decided in Miss. Ct. App..
- COURT
- Miss. Ct. App.
- DECIDED
- 2018
- CITATION
- 262 So. 3d 1135
- OUTCOME
- Excluded
- STANDARD
- Daubert / Rule 702
- CITED BY
- 8 later opinions (CourtListener)
Exclusion of the defendant's own proposed expert testimony in computer forensics, offered to rebut the State's examiners on how files came to be on his computer, was affirmed. The court upheld exclusion on the discovery-designation ground and expressly declined to reach the trial court's alternative finding that he was not qualified.
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READ THE OPINIONDonaldson v. State, 262 So. 3d 1135↗COURTLISTENER · FREE LAW PROJECT · OPENS IN THE SAME TAB
The court’s reasoning
After a Daubert hearing the trial court gave two reasons: failure to comply with expert-designation discovery requirements, and lack of qualification. Reviewing for abuse of discretion, the appellate court held the discovery ground alone sufficed and therefore did not address qualification.
From the opinion
“his counsel failed to comply with the discovery requirements”
Grounds argued
This ruling turned on 2 of the eight arguments that recur across the docket. Each is defined the same way on every entry, so the same ground can be followed across rulings that reached opposite results.
- Qualifications
- Whether this witness — by training, certification, or documented casework — is competent to give this opinion. Courts routinely admit examiners qualified by experience alone, and routinely narrow them when the opinion strays past the experience they described.
- Methodology
- Whether the steps the examiner took are a recognised way of answering the question asked, and whether they were followed as described. Most digital-forensics rulings turn on this rather than on anything the field would call science.
Practice note
Terms used on this page
Every term below is defined in the forensic glossary — what it is, why a case turns on it, and what happens in the matter when it is mishandled.
Rulings on the same grounds
One ruling is not a rule. These are the other entries in the docket argued on the same grounds, most-cited first — including the ones that came out the other way, which are the ones worth reading before relying on this entry for anything.
ON QUALIFICATIONS
- Kumho Tire Co. v. Carmichael 526 U.S. 137 (1999) EXCLUDED
- Wellogix v. Accenture 716 F.3d 867 (2013) ADMITTED
- Krause v. State 243 S.W.3d 95 (2007) ADMITTED
- United States v. Chiaradio 684 F.3d 265 (2012) ADMITTED
ON METHODOLOGY
- Daubert v. Merrell Dow Pharmaceuticals 509 U.S. 579 (1993) ADMITTED
- Kumho Tire Co. v. Carmichael 526 U.S. 137 (1999) EXCLUDED
- General Electric Co. v. Joiner 522 U.S. 136 (1997) EXCLUDED
- Wellogix v. Accenture 716 F.3d 867 (2013) ADMITTED
If an opinion in your case has to survive the argument this ruling turned on — or you need one tested before it is served — Law & Forensics retains court-tested digital forensic expert witnesses and forensic neutrals.
A conflicts check and scoping call follow, normally within one business day. Please do not send privileged or case-sensitive material until conflicts have cleared.
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The argument this docket is the evidence for: why an opinion stated one level too strongly is an admissibility problem under Rule 702(d).
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Twelve questions about an expert's methodology, mapped to the failure modes these rulings keep finding, with the remediation for each gap.
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Attorney advertising / expert services. Each entry summarises a decision as it appeared in the opinion linked from that entry, on the day the entry was written. Decisions are reversed, vacated, superseded, and distinguished, and the text of Federal Rule of Evidence 702 was itself amended effective 1 December 2023 — check the current status and subsequent history of any ruling before relying on it. Nothing here is legal advice, none of it is a prediction about how any court will rule, and it is not a substitute for the rules, standing orders and case law of your own forum.