## Facts

- Police found George Tyler dead and Rachel Tyler injured in their Norwalk home; the premises appeared ransacked and items including a wallet and jewelry were missing.
- Investigators collected physical evidence including broken glass and a section of linoleum bearing a bloody sneaker footprint.
- A plumber later found the victim’s credit cards clogging a toilet in the apartment where Wendell Hasan lived; police were notified.
- Police seized several pairs of shoes from the apartment, including size-11 Puma sneakers found in Hasan’s bedroom.
- The State offered circumstantial evidence that the Puma soles were consistent with the crime-scene footprint and had blood consistent with the victims’ blood.
- A podiatrist, Dr. Robert Rinaldi, examined the sneakers and Hasan’s feet and opined within reasonable podiatric certainty that the sneakers belonged to Hasan, based on wear patterns and foot characteristics.
- Rinaldi conceded the characteristics he relied on were common and that there was no recognized scientific methodology for “matching shoes to people,” and he had not previously testified or researched this type of identification.
- A jury convicted Hasan of felony murder and first-degree burglary.

## Issues

1. Whether the trial court abused its discretion by admitting a podiatrist’s expert opinion identifying sneakers as the defendant’s based on shoe wear and foot characteristics.
2. Whether the testimony constituted novel scientific evidence requiring a Frye-type general-acceptance showing, rather than ordinary admissibility standards for expert opinion.

## Decision

- The Connecticut Supreme Court affirmed the convictions.
- The court held the trial court did not abuse its discretion in admitting the podiatrist’s testimony.
- The court concluded a Frye-style threshold showing of general scientific acceptance was not required because the opinion was based on physical comparison that jurors could understand and assess.

## Legal Principles

- Frye-type general-acceptance screening is directed to evidence so technically or scientifically complex that jurors may be unable to evaluate it without deferring to an “aura” of scientific authority.
- Expert testimony grounded in observable physical comparison, where jurors can inspect the relevant items and evaluate the reasoning with common sense, ordinarily does not require a Frye general-acceptance determination.
- Experience-based expert opinion is admissible when the witness is qualified and the testimony assists the trier of fact; weaknesses in methodology and limits on probative value are addressed through cross-examination and rebuttal evidence.
- The fact that an expert uses a certainty formulation does not, by itself, transform comparison-based observations into novel scientific technique demanding Frye scrutiny.

## Conclusion

The court upheld the admission of a podiatrist’s shoe-fit identification testimony as comparison-based expert evidence helpful to the jury and subject to ordinary adversarial testing, not a novel scientific technique requiring proof of general acceptance under Frye.


State v. Hasan, 205 Conn. 485, 534 A.2d 877 (Conn. 1987)