Pennell V. State of Delaware, Term Paper

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" (Douglass & Munn, 1992). Furthermore, the signature aspects of a case can be more important than M.O. Or victimology in linking crimes, because criminals often change M.O. As they become more adept at committing their crimes. (Douglass & Munn, 1992). In addition, signatures can be more significant than differences or similarities between victims because "the offender expresses anger through rituals, not by attacking a victim who possesses a particular characteristic or trait." (Douglass & Munn, 1992).

The Pennell decision did not decide several related issues. For example, because the trial court limited the scope of the expert's testimony, the higher court did not have to determine whether or not profile evidence would be admissible. Although the Court did suggest that profile evidence would not be admissible, as the science of profiling becomes more advanced, such evidence may become admissible under Del. R. Evid.

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702 and under Frye. Furthermore, the Court did not address whether an expert would be permitted to testify regarding M.O. However, it appears that an expert would be permitted to give such testimony because the jury would already be in possession of the details making up the M.O. Of each of the charged crimes and an expert's specialized knowledge might help the jury understand those facts. However, the State should be cautious about seeking expert testimony regarding M.O. because prominent experts in the field suggest that M.O. is of little value in linking crimes. (Douglass & Munn, 1992)......

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