The attorney monitoring Virginia state law decisions for this site is Steven R. Minor, of Elliott Lawson & Minor. He will also be known to many visitors as the author of the excellent Southwest Virginia Law Blog.
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Beale v. Commonwealth, No. 1808-03-2 (Va. Ct. App. Apr. 20, 2004) (unpublished). In rape trial, prosecution offers testimony from sexual assault nurse examiner re causation of victim's injuries. Jury convicts. Admissibility affirmed. Defendant protests that trial court conducted no preliminary analysis of testimony's reliability. But scientific methods employed by witness were so familiar as to require no such preliminary findings. Defendant's quarrels with basis of expert's testimony went to weight, not admissibility.