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Name: People v. Jackson
Case #: B241930
Opinion Date: 12/03/2013
Court: CA Court of Appeal
District 2 DCA
Division: 5
Citation: 221 Cal.App.4th 1222
Summary

Expert testimony regarding “unknown offender assessment” was properly introduced to interpret evidence in murder case. In 1994, defendant’s wife, Marie, was murdered. Her body was found in the trunk of her locked Saab, which was parked at a beach with the battery removed. In 2005, DNA evidence from the crime scene was matched to defendant. At his trial in 2012, the trial court admitted the expert testimony of a former FBI agent, Safarik, who analyzed the crime scene. Safarik’s assessment did not focus on who committed the offense, but provided insight into potential motivation for the crime by analyzing the evidence from a behavioral and forensic standpoint. In part, Safarik opined that Marie was killed at her residence by one person who knew her, as the result of interpersonal aggression between her and the killer. The crime scene had been staged to make it appear the killing was for financial gain. By leaving Marie at the beach, the killer hoped police would conclude an unknown killer happened upon her by opportunity when she was jogging. Defendant was convicted of first degree murder. On appeal he challenged the admission of the expert testimony. Held: Affirmed. The admission of Safarik’s opinion was consistent with the reasoning in People v. Prince (2007) 40 Cal.4th 1179, which upheld the admission of expert testimony on crime scene analysis. The trial court could reasonably conclude that Safarik’s testimony would assist the jury and the testimony was not inadmissible based on the fact that the jury could draw its own common sense inferences from the evidence. Further, Safarik’s testimony was not inadmissible profile evidence that was irrelevant, lacked a foundation, or was more prejudicial than probative. Safarik did not compare defendant’s behavior to the characteristics of the killer and did not consider highly incriminating facts, such as the DNA evidence, in his analysis.