Formal Training Not Necessarily Required to Qualify an Expert

In affirming the conviction, the Second Department explained the discretionary criteria for qualifying an expert at trial, which does not necessarily depend upon formal training:

The qualification of a witness to testify as an expert is a matter that rests in the sound discretion of the trial court, and the court’s determination should not be disturbed on appeal in the absence of a serious mistake, an error of law, or an improvident exercise of discretion … . “The competence of an expert in a particular subject may derive from long observation and real world experience, and is not dependent upon formal training or attainment of an academic degree in the subject” … . People v Dorvilier, 2014 NY Slip Op 07517, 2nd Dept, 11-5-14