Section 23.45 Qualifications

• Library: Criminal Practice 2012 Supp

B. (§23.45) Qualifications

Qualification of an expert is a matter resting within the trial court’s discretion. State v. Schaefer, 855 S.W.2d 504 (Mo. App. E.D. 1993). The test of expert qualification is whether the expert has knowledge from education or experience that will aid the trier of fact. State v. Mallett, 732 S.W.2d 527, 537 (Mo. banc 1987), cert. denied, 484 U.S. 933 (1987). This expertise may have been gained by practical experience rather than by scientific study or research. State v. Rhone...