In State v. Sharpe, the supreme court held that Daubert/Coon determinations on the admissibility of scientific evidence should be subject to the independent judgment of the appellate court as to whether the underlying scientific theory or technique is scientifically valid under the first prong of the Daubert analysis.[1] The case consolidated three cases in which the defendants, Thomas Alexander, Jyzyk Sharpe, and Jeffery Holt, sought to admit a comparison question technique polygraph examination into evidence. A two-day evidentiary hearing was held on the admissibility of Alexander’s polygraph examination where it was determined that the evidence met the Daubert/Coon requirements for scientific validity. Subsequently, the State moved in Sharpe’s case to exclude his polygraph examination. No new evidentiary hearing was held as to Sharpe’s evidence; the superior court relied on the record and evidence presented in Alexander’s evidentiary hearing. The superior court held the examination admissible on the same reasoning. A third superior court examined the same record and order in Alexander’s evidentiary hearing to determine the admissibility of Holt’s polygraph examination. The court determined that the evidence was not sufficiently reliable to be admitted. Parties filed appeals in all three cases. The court of appeals urged the supreme court to reconsider the prior standard of review established in State v. Coon, abuse of discretion. The supreme court held that the prior standard of review understated the potential for inconsistent rulings on the admissibility of scientific evidence to a level that undermined the integrity of the court. The court determined that the dissent in Coon correctly identified that the abuse of discretion standard would likely lead to inconsistent application in similar situations. The court reasoned that the posture of these three cases, which relied on the same evidentiary hearing but arrived at different results, demonstrated this inconsistency. The supreme court held that Daubert/Coon determinations on the admissibility of scientific evidence should be subject to the independent judgment of the appellate court as to whether the underlying scientific theory or technique is scientifically valid.
[1]435 P.3d 887 (Alaska 2019).
