context: Here, the proposed expert is to testify about GPS coordinates and analysis. Under the caselaw, this subject matter does not require scientific, technical or specialized knowledge.
citation_a.signal: see also
citation_a.identifier: 699 F.3d 588, 612-13
citation_a.parenthetical: explaining that issues surrounding GPS and its accuracy are not so scientific that an expert is necessary
citation_a.sentence: United States v. Thompson, 393 Fed.Appx. 852, 858, 859 (3d Cir.2010) (holding that the trial court properly allowed lay witness testimony concerning the operation of a GPS device, including authentication of the GPS’s data); see also United States v. Espinal-Almeida, 699 F.3d 588, 612-13 (1st Cir.2012) (explaining that issues surrounding GPS and its accuracy are not so scientific that an expert is necessary).
citation_b.signal: no signal
citation_b.identifier: 393 Fed.Appx. 852, 858, 859
citation_b.parenthetical: holding that the trial court properly allowed lay witness testimony concerning the operation of a GPS device, including authentication of the GPS's data
citation_b.sentence: United States v. Thompson, 393 Fed.Appx. 852, 858, 859 (3d Cir.2010) (holding that the trial court properly allowed lay witness testimony concerning the operation of a GPS device, including authentication of the GPS’s data); see also United States v. Espinal-Almeida, 699 F.3d 588, 612-13 (1st Cir.2012) (explaining that issues surrounding GPS and its accuracy are not so scientific that an expert is necessary).