People v. Caldwell
In People v. Caldwell, 43 P.3d 663, 668 (Colo. App. 2001), police recovered two bullets from the vehicle, and an investigating officer testified regarding "the appearance and location of the two bullet holes on the outside of the car, the hole inside the car, and the dimpling of the metal inside the car.
From his own observations and the use of a dowel and string, the technician testified that he tracked the paths of the two bullets." Id. at 667.
The Colorado Court of Appeals (affirming the conviction) held that although the officer had not been qualified as an expert, none of the information that he testified to required that he rely on his expertise--and "he testified about the location of the bullet holes and the paths of the bullets that were evident from the photographs without any additional explanation." Id. at 668.