State v. Rangel

Rangel’s conviction was based on the testimony of Whitaker and Scott, who testified as to the falsity of Rangel’s Social Security card and green card. Although Rangel strenuously objected to their qualifications to testify regarding the authenticity of the documents, the judge allowed the testimony.

Expert testimony is governed by Evid.R. 702. The rule outlines three requirements necessary for expert testimony to be admissible. First, the testimony must either “[relate] to matters beyond the knowledge or experience possessed by lay persons or [dispel] a misconception common among lay persons.”…