What is the test for an expert's analysis of crime scene data at a jury trial?

Defendant challenges this analysis on three grounds. First, he argues that the expert's testimony is unreliable because it is not scientific. But the Evidence Code permits expert testimony to be grounded in experience as well as science. ( 720; People v. Prince (2007) 40 Cal.4th 1179, 1219-1220 (Prince) [experience-based testimony permitted].) Second, defendant contends that the expert's testimony is unreliable, and the only reason the trial court did not come to the same conclusion is because it erroneously excluded several academic articles defendant offered

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against the expert's testimony. Without a witness to lay foundation for those articles, they were hearsay and thus well within the court's discretion to exclude. ( 1220.) Even if the studies had been admitted and considered, in light of Jackson, supra, 221 Cal.App.4th 1222, the court would not have abused its discretion in rejecting those articles and in admitting the expert's testimony. Lastly, defendant asserts that the expert's testimony was unnecessary because jurors could look at the crime scene evidence and draw the same conclusions as the expert. However, "'the jury need [not] be wholly ignorant of the subject matter'" before an expert may testify (People v. Brown (2014) 59 Cal.4th 86, 101), for in such circumstances, it may "aid [the jury] to learn from a person with extensive training in crime scene analysis" (Prince, at p. 1223).

2. Lack of general acceptance in the scientific community