Testimony by Experts

A witness qualified as an expert by knowledge, skill, experience, training, education or otherwise may testify in the form of an opinion or otherwise concerning scientific, technical or other special- ized knowledge, if the testimony will assist the trier of fact in understanding the evidence or in determining a fact in issue. COMMENTARY The subject matter upon which expert witnesses may testify is not limited to the scientific or technical fields but extends to all areas of specialized knowledge. See, e.g., State v. Edwards, 325 Conn. 97, 126–28, 156 A.3d 506 (2017) (explaining what qualifies as expert testimony); see also State v. Correa, 241 Conn. 322, 355, 696 A.2d 944 (1997) (federal agent properly allowed to testify about local cocaine distribu- tion and its connection with violence); State v. Hasan, 205 Conn. 485, 494–95, 534 A.2d 877 (1987) (podiatrist properly allowed to testify about physical match between shoe and defendant’s foot). Section 7-2 requires a party offering expert testimony, in any form, to show that the witness is qualified and that the testimony will be of assistance to the trier of fact. A three part test is used to determine whether these requirements are met. E.g., Sullivan v. Metro-North Commuter Railroad Co., 292 Conn. 150, 158, 971 A.2d 676 (2009). First, the expert must possess knowledge, skill, experience, training, education or some other source of learning directly applicable to a matter in issue. E.g., Weaver v. McKnight, 313 Conn. 393, 406–409, 97 A.3d 920 (2014); State v. Borrelli, 227 Conn. 153, 165–67, 629 A.2d 1105 (1993); State v. Girolamo, 197 Conn. 201, 214–15, 496 A.2d 948 (1985). Second, the witness’ skill or knowledge must not be common to the average person. See, e.g., State v. Guilbert, 306 Conn. 218, 230, 49 A.3d 705 (2012); State v. Borrelli, supra, 167–71. Third, the testimony must be helpful to the fact finder in considering the issues. See, e.g., State v. Hasan, supra, 205 Conn. 494 (‘‘[t]he value of [the witness’] expertise lay in its assistance to the jury in reviewing and evaluating the evidence’’). The inquiry is often summa- rized in the following terms: ‘‘The true test of the admissibility of [expert] testimony is not whether the subject matter is com- mon or uncommon, or whether many persons or few have some knowledge of the matter; but it is whether the witnesses offered as experts have any peculiar knowledge or experience, 27 Connecticut Code of Evidence