Phillips ex rel. Utah State Department of Social Services v. Jackson
In Phillips ex rel. Utah State Department of Social Services v. Jackson, 615 P.2d 1228 (Utah 1980), the Court held that a lab technician with a bachelor of science degree in bacteriology, who worked at the lab that conducted the paternity test at issue, was not qualified to testify to the validity of the paternity test. Id. at 1236.
In Phillips, the Court held that the lab technician was "clearly not qualified to testify with respect to the basic validity of the paternity test." Id.
However, the Phillips court did not disqualify the testimony because the lab technician did not have an advanced degree.
Rather, the Phillips court disqualified the technician as an expert because the technician's "work with HLA tissue typing was used in connection with organ transplantation," not paternity identification, and "it was not possible to discern from the record whether the reliability claimed for HLA tests in determining tissue compatibility in organ transplants is transferable to paternity identification." Id.