United States v. Aman

United States District Court for the Eastern District of Virginia · 2010 · Evidence

748 F. Supp. 2d 531 (E.D. Va. 2010)

Updated August 22, 2026

EvidenceExpert testimonyDaubertRule 702NFPA 921ACE-VGC/MSfire investigation

Facts

After a fire at Bridges Billiards & Grill, fire officials found bottles of charcoal lighter fluid on the premises, smelled ignitable liquids on the defendant, and discovered fire damage in separate locations. Fire investigator Lt. George Robbins examined the scene, observed irregular burn patterns and odors of ignitable fluid, and recovered items including matches, a partially burned shirt smelling of ignitable liquid, and part of a bottle containing liquid that smelled like gasoline. Fingerprint specialist Charles Kubilus compared latent prints recovered from Bridges to the defendant's known prints and concluded that all but one palmprint matched the defendant. Forensic scientist Andrew Hawkins used gas chromatography/mass spectrometry on debris and clothing recovered from the scene and found gasoline present in much of the evidence.

Issue

Whether the testimony of the government's fire investigator, fingerprint analyst, and forensic chemist was admissible under Rule 702 and Daubert. More specifically, the court considered whether each expert used sufficiently reliable principles and methods and applied those methods reliably to the facts of this case.

Rule

Under Rule 702, expert testimony is admissible if it is based on sufficient facts or data, is the product of reliable principles and methods, and the expert has applied those principles and methods reliably to the facts of the case. Daubert's reliability inquiry is flexible and focuses on methodology rather than conclusions, with testing, peer review, standards, error rate, and general acceptance as relevant but nonexclusive factors; weaknesses that go to weight rather than admissibility are ordinarily addressed through cross-examination and contrary evidence.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

After a warehouse fire in Columbus, Ohio, the prosecution offers Nina Torres, a certified fire investigator. She testifies that she followed NFPA 921 by documenting the scene, collecting data, developing and testing hypotheses, and ruling out accidental causes before concluding the fire was intentionally set.

The defense moves to exclude Torres's testimony solely because fire investigation lacks a precise, universally accepted error rate. How should the court rule?

Explanation. Rule 702 requires reliable principles and methods and reliable application. The opinion treated Daubert's factors as flexible, not a checklist. It specifically held that NFPA 921 is reliable because it is peer reviewed, generally accepted, and uses hypothesis generation and testing, even though a known error rate was not established. Thus the absence of a precise error rate alone does not require exclusion.