## Facts

- Binta Maryam Baraka was indicted in Fayette Circuit Court for the murder of Brutus Price.
- The prosecution alleged that stress from a physical altercation between Baraka and Price precipitated Price’s fatal heart attack.
- The state medical examiner, Dr. Cristin Rolf, concluded the cause of death was heart attack and the manner of death was homicide (described as “homicide by heart attack”).
- Baraka requested a pretrial Daubert hearing to exclude Dr. Rolf’s opinion as unreliable and unhelpful to the fact-finder.
- After the hearing, the trial court ruled Dr. Rolf’s testimony admissible under Kentucky’s modified Daubert framework.
- Baraka entered conditional guilty pleas to second-degree manslaughter and second-degree persistent felony offender and received a 10-year sentence.
- The Court of Appeals affirmed, and discretionary review was granted limited to the Daubert admissibility ruling.

## Issues

1. Whether the trial court erred or abused its discretion under Kentucky’s modified Daubert standard by admitting the medical examiner’s opinion that the manner of death was homicide based on a stress-induced heart attack.

## Decision

- The Kentucky Supreme Court affirmed.
- The trial court’s reliability determination was supported by the record and was not clearly erroneous.
- The trial court did not abuse its discretion in finding the testimony would assist the trier of fact, even though it touched an ultimate issue.

## Legal Principles

- Kentucky applies a modified Daubert approach requiring a qualified expert, reliable methodology, relevance with probative-value balancing, and assistance to the trier of fact.
- Appellate review of a Daubert ruling is for abuse of discretion; a ruling is an abuse only if arbitrary, unreasonable, unfair, or unsupported by sound legal principles.
- Under Miller v. Eldridge, reliability determinations are reviewed for clear error, while the “assistance to the trier of fact” determination is reviewed for abuse of discretion.
- Expert testimony may embrace an ultimate issue if it is helpful and grounded in reliable scientific or technical reasoning, rather than a bare legal conclusion.

## Conclusion

The court held that admitting forensic pathology testimony characterizing a stress-induced heart attack as a homicide was within the trial court’s gatekeeping discretion where the theory was supported by professional acceptance, literature, and a scientific explanation that aided the jury.


Baraka v. Commonwealth, 194 S.W.3d 313 (Ky. 2006)