Court Filing
EXHIBIT S-13 Amended Supplemental Expert Disclosure: Hailey Youngling The State has previously disclosed Hailey Youngling, Forensic Scientist I, as an expert witness in the field of forensic science, which includes, but in no way is limited to, latent prints, buccal swab collection, and scene processing. The State hereby incorporates its previous responses and attachments field on December 18, 2024, and is hereby supplementing its response as follows. Youngling may discuss the process of photographing crime scenes. The purpose of processing the crime scene is to collect as much information and evidence as possible, in as pristine a condition as possible. The process involves assessing the situation and the scene; observing the condition of the scene; documentation of the scene via photography, written observation, sketches or diagrams; searching systematically for items or materials that may have evidentiary value; collecting items in a way that will preserve them and prevent alteration, contamination and tampering; and chemical or physical processing if needed to detect evidence that is not readily visible. Items that may have evidentiary value are identified, documented and collected. Effort is made to ensure that items are preserved as found. The type and size of packaging are determined based on the type of evidence. Cigarette butt- paper evidence envelope. Paper note / receipt- paper evidence envelope. Computer and electronics components- paper evidence envelope or paper bag, depending on size and examination (s) to be completed. Larger items, like computer towers or monitors, that do not fit into standard evidence bags, may be identified with an evidence tag. Nitrile type glove- paper evidence envelope. Vacuum dust container- paper evidence bag. STATE'S EXHIBIT exhibitsticker.com EXHIBIT S-13 Amended Supplemental Expert Disclosure: Hailey Youngling (Sealed) S-13 1 CR01-24-31665 Items may be processed for latent prints on scene or collected for future processing in the laboratory. Latent print evidence can be developed on scene by using light enhancement, powder or blood enhancing chemicals (amido black). Observed or developed prints are preserved with photography and / or tape lifting. Preserved impressions can be used for further latent print analyses. DNA evidence may be collected at a crime scene if there is observable biological material in the form of blood, semen, saliva, hair or other tissue present. Some biological material may not be visible but may be collected for its “ possible ” presence. “ Possible ” DNA material refers to areas or items that are likely to have DNA based on the details of the case or known activities. “ Potential ” DNA material refers to areas or items that may have DNA based on how they may have been handled (touch DNA). Biological / DNA material on a smaller item is generally collected by collecting the entire item (e.g. shirt, weapon, bottle). Visible biological / DNA material on a structural surface (e.g. floor, wall) or on a large object (e.g. furniture) is generally collected by using one or two sterile cotton swabs simultaneously. The swabs may be moistened with sterile water prior to sample collection. After swabbing the surface, the swabs are allowed to air dry in porous packaging. Any biological / DNA material on those swabs is preserved and can be used for future testing. Collection of “ possible ” and “ potential ” DNA are collected in the same method as described for visible DNA, using sterile water and sterile swabs. Deoxyribonucleic acid (DNA) is genetic material contained in human cells that may be utilized for human identification. DNA may be present on an item in the form of biological materials such as blood, semen, and saliva or may be left on an item when it is handled (touch DNA). Biological evidence and possible / potential DNA evidence is EXHIBIT S-13 Amended Supplemental Expert Disclosure: Hailey Youngling (Sealed) 2 collected for preservation and may be sent for further testing by qualified DNA analysts. Crime Scene personnel do not test for DNA specifically. Presumptive blood tests are chemical tests that are used to distinguish possible blood stains from non-blood stains. The chemical tests used are phenolphthalein or Orthotolidine. These tests are considered presumptive because the chemicals react to blood, which indicates the material may be blood. They are not specific for blood meaning they could react with a substance that is not blood. A small sample of a stain is collected onto a swab or filter paper, and the chemicals are applied to the sample; this leaves the source stain unaffected by chemicals. If the chemical has a color change (pink for phenolphthalein or blue / green for Ortho-tolidine) the stain is considered “ presumptively ” positive for blood. The stain or item may be collected for future biological testing. If a test is inconclusive, the item / stain would likely be collected for further laboratory testing. If the test is negative, the item / stain would likely NOT be collected. Trace materials like hairs or fibers may be present at a scene or on an item. These items can be collected with forceps and / or adhesive material and packaged for potential analysis. Shoe and tire impressions evidence may be observed or developed using chemical (amido black, leucocrystal violet, etc.) or physical methods (powder or light enhancement). Preservation methods include photography, casting and lifting. Buccal cells are found on the inside of a person's cheek. A sterile cotton swab, or pair of swabs, is used to collect these cells as a reference DNA sample from a known individual. Buccal swab samples can be compared to unknown DNA samples from a crime scene or from an item of evidence. EXHIBIT S-13 Amended Supplemental Expert Disclosure: Hailey Youngling (Sealed) 3 Known hair samples may be collected from a subject for use as a reference sample for hair analysis or biology testing. Hairs are collected by pulling a sampling of hairs from various parts of the body and preserving them for future analyses. Youngling will also discuss the examination of latent prints, including exemplars, print comparison, ridge detail, verification, and the Multi-Modal Biometric Identification System (MBIS). Additionally, Youngling may discuss lab protocols and procedures including the disposition of evidence. Friction ridge skin is a specialized type of skin on the hands and feet that is capable of being used to establish or confirm their identity. This skin consists of ridges and valleys located on the gripping surfaces of the hand and feet that form patterns. Fingerprints are classified into the following pattern types: arches, loops, and whorls. Individual ridges have features or characteristics (minutiae) that are highly discriminating between individuals. These features are formed prior to birth and remain relatively unchanged throughout one's life barring trauma or disease. Friction Ridge detail refers to the features and characteristics present in friction ridge impressions. This detail may be described as level 1 (direction of ridge flow), level 2 (ridge path), level 3 (ridge shape and pore location). Friction ridge details permit comparison and subsequent identification of fingerprints. Latent prints are impressions of friction ridge skin patterns that can be left on a surface when contact is made. The term “ latent ” refers to prints that are not visible prior to utilizing a development method; latent prints are often made up of various matrices, including sweat and oils that are colorless and require development with chemicals or powders to be seen. Prints at a crime scene may also be made from other materials that EXHIBIT S-13 Amended Supplemental Expert Disclosure: Hailey Youngling (Sealed) 4 may coat the skin, like blood or dirt. Although latent means hidden, any prints recovered from a crime scene or from items of evidence are often referred to as latent prints. Exemplars are intentional recordings of the friction ridge skin of an individual. These may be collected with black ink, powder / adhesive, electronic imaging, and / or other capture methods. These known exemplars can then be used for comparison against latent print evidence. Exemplars may include any / all areas of friction ridge skin from the hands or feet of an individual. Types of exemplars include fingerprints, palm prints, major case prints (tips, joints, sides of fingers), and footprints. Latent print comparison refers to the process of analyzing latent prints and comparing them to known exemplars in attempt to determine their source. Examiners utilize the ACE-V methodology which is a specialized version of hypothesis testing. ACE- V stands for analysis, comparison, evaluation and verification. Analysis is the assessment and documentation of friction ridge impressions to determine suitability for comparison. This assessment includes consideration of the quality and quantity of detail, orientation, anatomical source (finger, palm, etc.), type of matrix, deposition factors, complexity, substrate considerations, environmental factors, development mediums, and preservation methods. Latent prints may be of value for comparison or may be deemed to contain insufficient detail for comparison purposes. Impressions deemed " of value " are impressions that in the opinion of the examiner, contain sufficient quantity, quality, and specificity of ridge detail to warrant a comparison. Examiners also take into consideration how discriminating the location and arrangement of features within an impression are. When quantity is low, quality must be relatively high. Whereas when quality is low, quantity must be relatively high. It is not uncommon for EXHIBIT S-13 Amended Supplemental Expert Disclosure: Hailey Youngling (Sealed) 5 latent print examiners to have conflicting opinions with regards to sufficiency. Latent prints are also evaluated for their suitability for database entry (AFIS, ABIS, MBIS, etc.) Comparison is the side-by-side, back and forth, examination of friction ridge detail between a latent print and a known print to determine whether the detail is in agreement or disagreement based upon features, sequences, and spatial relationships within the tolerance of clarity and distortion. Generally, latent prints are first compared against various known prints belonging to subjects associated with the evidence (victims, witness, and / or suspects if known). In the event that the latent prints are not identified or that there are no known prints available with which to compare, the prints may be entered into a computer database (MBIS) and compared to a large group of persons who have prints on file. Evaluation is the formulation of a conclusion based upon analysis and comparison of friction ridge impressions. Conclusions that may be reached are source identification, source exclusion or inconclusive. Source identification is the examiner's opinion that two impressions originated from the same source. The observed features are in sufficient correspondence such that the examiner would not expect to see this level of agreement in impressions that came from different sources. Nor did the examiner find features in disagreement that would lead them to conclude that the impressions are from different sources. There is no scientific basis for a predetermined number of corresponding friction ridge details be present in two impressions in order to effect a source identification. Source exclusion is an examiner's conclusion that two impressions did not originate from the same source. The observed features are in disagreement such that the examiner would not expect them to have originated from the same source. Inconclusive is an examiner's inability to reach a conclusion of source identification or exclusion. Inconclusive may be EXHIBIT S-13 Amended Supplemental Expert Disclosure: Hailey Youngling (Sealed) 6 due to lack of quantity or quality of detail in the latent or known impression. Verification is the independent examination by another qualified analyst using the ACE methodology to either support or refute the conclusions of the original examiner. ISPFS requires verification of all conclusions rendered in a case (value determinations, identifications, exclusions and inconclusives). Routine verification is considered “ open ”. This means the verifier conducts independent analysis but has access to the original analyst's notes and images. Blind verification, in which the verifier has no knowledge of or access to the original analyst's conclusion, may be performed in cases of single identifications generated from a database, as a means of conflict resolution, or as an additional quality measure for complex impressions. The decisions made at the evaluation step is an examiner's opinion based on their personal observations. These observations may be influenced by training, experience, risk tolerance, bias and many other factors. Once this decision is made, the case is sent to another qualified analyst for verification. It is not uncommon for analysts to have different opinions and come to differing conclusions during the ACE-V process. ISPFS has a conflict resolution policy for navigating and documenting such instances. Analysts are encouraged to resolve differing opinions by re-examination and / or discussion to arrive at a mutually agreed upon conclusion that is supported by the observed data. When this cannot be achieved, a blind verification by an additional analyst may be conducted. If blind verification does not result in a resolution, a consensus opinion or administrative opinion may be sought. The Multi-Modal Biometric Identification System (MBIS) is the general term referring to any system that contains a database of ten-print, latent prints and palm prints. EXHIBIT S-13 Amended Supplemental Expert Disclosure: Hailey Youngling (Sealed) 7 MBIS also includes software that is utilized to search available databases. Idaho is a member of the Western Identification Network and is able to search the databases of WIN central site members and the FBI. MBIS allows for searching latent prints against known fingerprint and palm print database records. The system can also be used to search latent prints against other latent prints. EXHIBIT S-13 Amended Supplemental Expert Disclosure: Hailey Youngling (Sealed) 8