Stevenson v. State
Stevenson v. State, 222 Md. App. 118, 112 A.3d 959 (2015). Decided in Md. Ct. Spec. App..
- COURT
- Md. Ct. Spec. App.
- DECIDED
- 2015
- CITATION
- 222 Md. App. 118, 112 A.3d 959
- OUTCOME
- Admitted
- STANDARD
- State Rule 702 analogue
- CITED BY
- 1 later opinions (CourtListener)
The circuit court did not abuse its discretion in qualifying a detective as an expert in digital forensics and permitting him to testify to the Cellebrite extraction of a cell phone and the report generated from it.
Every entry in this docket was written from the opinion itself, and this is the copy that was read. If the opinion does not support what is written here, the entry is wrong — tell us and it will be corrected or removed rather than softened.
READ THE OPINIONStevenson v. State, 222 Md. App. 118, 112 A.3d 959↗COURTLISTENER · FREE LAW PROJECT · OPENS IN THE SAME TAB
The court’s reasoning
The court credited twenty years of police experience, four years specifically in cell-phone forensics, named certifications including Cellebrite, a prior qualification as a digital-forensics expert, and analysis of over a thousand phones. It rejected the argument that device-limited training and a single prior qualification were disqualifying, relying on an earlier decision approving comparable on-the-job credentials.
From the opinion
“The Circuit Court Did Not Abuse Its Discretion In Qualifying Detective Allen As An Expert Witness.”
Grounds argued
This ruling turned on one 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.
Practice note
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
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.
- The Daubert Docket
All 55 rulings, filterable by ground, outcome and court, with the distribution across the three outcomes reported up front.
- Daubert and digital evidence
The argument this docket is the evidence for: why an opinion stated one level too strongly is an admissibility problem under Rule 702(d).
- Daubert Exposure Check
Twelve questions about an expert's methodology, mapped to the failure modes these rulings keep finding, with the remediation for each gap.
- Daubert or Frye?
Which reliability test your forum applies — settle that before relying on a ruling from another jurisdiction.
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.