Investigator Testimony About Hit-And-Run Crimes

In Anderson v. State, 841 So. 2d 390 (Fla. 2003), an investigator testified that based on his training, it was not typical to find evidence of a hit-and-run accident on both sides of the road ninety feet apart, and thus he did not think that the crime scene was a hit-and-run traffic homicide. The Court held that this opinion testimony was admissible because it was not about past crimes or criminal patterns, but rather about the investigator's experience investigating hit-and-run crimes. Id. at 400-01.