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FEDERAL DISTRICT · 200944 / 55

United States v. Collins

United States v. Matthew Joseph Collins, 753 F. Supp. 2d 804 (2009). Decided in S.D. Iowa.

COURT
S.D. Iowa
DECIDED
2009
CITATION
753 F. Supp. 2d 804
OUTCOME
Admitted
STANDARD
Other (Rule 901, 403, or state rule)
CITED BY
0 later opinions (CourtListener)
THE HOLDING

The defence's proffered computer-forensics witness met the minimal qualifications of Rule 702 by knowledge, experience and training, despite having no relevant degree and no forensic examiner certification, and was permitted to offer his opinions on the motion. The court separately recorded that the defence withdrew its challenge to SHA-1 hash comparison.

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READ THE OPINIONUnited States v. Collins, 753 F. Supp. 2d 804

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The court’s reasoning

Qualification rested on hands-on experience in computer programming and forensic evaluation rather than credentials, and the court noted the credential gaps expressly rather than glossing them. On hash reliability, the defence's own forensic computer expert agreed with the government agent that SHA-1 values are in excess of 99.9999 percent accurate, and the challenge was abandoned.

From the opinion

for purposes of the current motion, the Court finds Mr. Chatten meets minimal qualifications as an expert, by knowledge, experience, and training, to offer the opinions herein.

United States v. Matthew Joseph Collins, 753 F. Supp. 2d 804 (2009)

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.
Tool reliability
Whether the software or hardware used — an imaging tool, a carving engine, an extraction platform — produces accurate results, and whether the examiner can say how that is known. Courts rarely require a tool to be validated from first principles, but they do expect the examiner to know its limits.

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.

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.

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