Missouri Court of Appeals, Western District / Sep 25, 2018
State of Missouri vs. William Carter
William Carter appealed his conviction for first-degree trespass, arguing the trial court improperly prohibited him from using the NAS Report to cross-examine the State's fingerprint expert. Carter contended the report was a learned treatise and that the court should have taken judicial notice of it under section 490.150. The appellate court affirmed, holding that Carter failed to establish the report's authoritativeness and that section 490.150 only addresses document authentication, not scientific authoritativeness.