IN THE UNITED STATES DISTRICT COURT



FOR THE DISTRICT OF NEW MEXICO





UNITED STATES OF AMERICA,



Plaintiff,



-vs- xxxxxxxxxxxxxx



xxxxxxxxxxxxxxxx,



Defendant.







MEMORANDUM OF POINTS AND AUTHORITIES

IN SUPPORT OF DEFENDANT'S MOTION FOR ADMISSION

OF EXPERT OPINION EVIDENCE REGARDING POLYGRAPH RESULTS



i. factual context.

The indictment accuses xxxxxxx, an Albuquerque dentist, of willfully under reporting income and thereby evading payment of income taxes. The alleged unreported income relates to reimbursement to him of office rent and hygienists' salaries by other dentists working in his office complex. There is no serious issue in this case that the monies involved constituted reportable income. The central issue in this case relates to whether Dr. xxxxxxxx realized that reportable income had not been included on the tax returns prepared by his accountant. The defense evidence will be that Dr. xxxxxxxx did not realize this fact until much later, during the IRS audit herein, when his accountant informed him the monies should have been reported as income. The question whether Dr. xxxxxxxx concealed information about this income from his accountant (he did not) will be addressed in part by the accountant, xxxxxxxx, at trial, and is summarized in the affidavit of Mr. xxxxxxxx attached hereto as Exhibit "A." The sole remaining issue is one of Dr. xxxxxxxx's intent, essentially whether he realized at the time the returns were filed that the returns underreported taxable income.

The issue is a crucial one. In Cheek v. United States, 489 U.S. 192, 111 S. Ct. 604 (1991), the United States Supreme Court held that the "willfulness" element requires that the jury determine whether the evidence shows, inter alia, that the defendant knew of his lawful duty regarding proper tax reporting and payment and that he voluntarily and intentionally violated that duty.

Dr. xxxxxxxx was the subject of a polygraph examination administered to him on August 10, 1994, by Dr. David Raskin, a qualified and experienced polygraph examiner, a laboratory and field researcher on the subject, a professor of psychology at the University of Utah and one of the world's foremost authorities on the scientific basis and applied use of polygraphs. A copy of Dr. Raskin's curriculum vitae is attached hereto as Exhibit "B." The purpose of the examination was to determine whether or not Dr. xxxxxxxx intentionally attempted to evade the payment of taxes. Dr. xxxxxxxx passed the examination with results that Dr. Raskin determined to be conclusively truthful. A summary of that examination is attached hereto as Exhibit "C." A copy of the summary, the polygraph charts, and a tape recording of the pretest interview and the polygraph test have previously been furnished to the government. At the evidentiary hearing requested by this motion, Defendant will introduce testimony from Dr. Raskin regarding his qualifications, the reliability of polygraph evidence, the scientific basis for the evidence and other pertinent criteria relevant to the determination of the admissibility of scientific polygraph evidence.

This evidence will be presented to comply with the new standards articulated by the United States Supreme Court in Daubert v. Merrell Dow Pharmaceuticals, Inc., ____ U.S. ____, 113 S. Ct. 2786 (1993), governing the admissibility of scientific evidence in federal trials.

ii. the new daubert standard and the demise of frye.

Admissibility of not only polygraph evidence, but scientific evidence in general has been governed in the federal courts for over half a century by the principles of the opinion in Frye v. United States, 293 F.2d 1013 (1923). Frye ruled inadmissible a simple and crude precursor to the modern polygraph test, on the ground that expert opinion based on a scientific technique would be inadmissible unless the technique is "generally accepted" as reliable in the relevant scientific community.

In large part, Frye has kept polygraph evidence out of federal trials, despite the development of knowledge about the scientific principles underlying the modern polygraph, and the extensive testing and development of techniques to apply that scientific knowledge.

Last year, the United States Supreme Court finally put Frye to rest. A Ninth Circuit opinion had upheld the exclusion of expert scientific testimony regarding whether birth defects were caused by an anti-nausea drug. The Ninth Circuit based its decision on Frye and the fact that the testimony of the expert was not based on principles sufficiently established to have general acceptance in the relevant scientific community.

The Supreme Court granted certiorari, "in light of sharp divisions among the courts regarding the proper standard for the admission of expert testimony." 113 S. Ct. at 2792. The Supreme Court reversed the Ninth Circuit and held that the Federal Rules of Evidence, not Frye, provided the standards for the admissibility of expert testimony. The Court stated that although the Frye "general acceptance" test had historically been the dominant standard for determining the admissibility of novel scientific evidence at trial, Fed. R. Evid. 702 superseded Frye and now governs admission of expert testimony. The rigid "general acceptance" requirement would be at odds with the "liberal thrust" of the Federal Rules, including their "general approach of relaxing the traditional barriers to `opinion' testimony." 113 S. Ct. at 2793.

The Court went on to note that its decision does not mean that there are no limits on the admissibility of purportedly scientific evidence. Indeed, the Court referenced numerous criteria which may assist the trial court in the exercise of its discretion. The Court observed:

The inquiry envisioned by Rule 702 is, we emphasize, a flexible one. Its overarching subject is the scientific validity--and thus the evidentiary relevance and reliability--of the principles that underlie a proposed submission. The focus, of course, must be solely on principles and methodology, not on the conclusions that they generate.113 S. Ct. at 2797.

The Supreme Court's explicit rejection of Frye and the opinions of those courts which relied on its reasoning necessarily mandates a fresh look at the scientific realities which call for admission of the polygraph examination in this case.

In the Tenth Circuit, prior to Daubert, polygraphs have historically not been admitted because of insufficient evidentiary showing of its reliability there was no per se rule of exclusion regarding polygraph test results. U.S. v. Hall, 805 F.2d 1410, 1416 (10th Cir. 1986) (Polygraph inadmissible to show that one is truthful, although "in a proper case, the evidence might be admissible,"); quoting U.S. v. Wainwright, infra, with approval, U.S. v. Wainwright, 413 F.2d 796 (10th Cir. 1969) cert. denied, 396 U.S. 1009 (1969) (Polygraph not admitted because defendant produced expert testimony to lay a predicate as to developing scientific standards and the probative value of the evidence, i.e., that the proposed test is an accepted one in the profession and that it has a reasonable measure of precision in its indications). There have been no post-Daubert decisions in the Tenth Circuit applying the Daubert standards to resolve the issue either way.

An examination of those standards demonstrates that the polygraph evidence in this case should be admitted for the jury's consideration.

iii. the daubert considerations and standards summarized.

The salient points from Daubert which are applicable in this case are: