Victor Rodrigues v Delaware, No. 603 (2010)


Rodriguez contends that the trial judge committed reversible error by allowing Hegman to testify as an expert in tire track and shoeprint analysis. Rodriguez argues that tire track and shoeprint analysis are part of a "separate and distinct forensic science discipline" as compared to fingerprint analysis and that "as experienced as Hegman may be in many aspects of fingerprint analysis, he was not qualified to be an expert in the field of footprint and tire track identification." Rodriguez also challenges the trial judge's description of Hegman as having a "trained eye."

Hegman's expertise in fingerprint analysis was relevant to his experience with impression evidence. While tire track and shoeprint analysis may be viewed as a distinct forensic discipline from fingerprint analysis because it involves mass-produced items, the analytic process is similar. Specifically, tire tracks, shoeprints, and fingerprints are all forms of impression evidence.10 Forensic analysis of fingerprints "consists of experience-based comparisons of impressions left by the ridge structures" of hand surfaces.11 Tire track and shoeprint analysis, like fingerprint analysis, seeks to identify the source of the impression by identifying and comparing particular characteristics.12 Hegman compared castings of the tracks and prints found at the fires to direct physical evidence: Rodriguez's boots and bike tires. He explained his process of measuring and then comparing specific characteristics between the impressions and the physical evidence. Thus, while Hegman's substantial experience in fingerprint analysis does not alone support his admission as an expert in other forms of impression analysis, the trial judge did not abuse his discretion in considering that experience and training as relevant.


The judgment of the Superior Court is AFFIRMED.

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