State v. Hollen
In State v. Hollen, 2002 UT 35, 44 P.3d 794, the Court held that the trial court's ruling excluding the expert's opinion did not exceed the "limits of reasonability," after placing the "trial court's decision in its proper context." Id
The Court considered that the expert was permitted to give extensive testimony regarding the factors affecting the reliability of eyewitness identifications, and was only limited in expressing his overall opinion on eyewitness identification. Id.
Since the expert in Hollen had already been given an opportunity to educate the jury on the impact of eyewitness identification, the Court found that the trial court did not abuse its discretion. Id. In Hollen, the trial court allowed the defendant's eyewitness identification expert to give "extensive testimony on factors that affect the reliability of identifications" but prohibited the expert from testifying on the "overall reliability of the process of identification." Id.
On review, the Court concluded that the trial court appropriately exercised its discretion because the excluded testimony would not have been "helpful to the finder of fact." Id.