During a trial for possession of cocaine for the purpose of trafficking, the Crown brought an application to qualify a police officer as an expert in the use, pricing, sale, and distribution of cocaine.
The court dismissed the application without a formal voir dire, finding that the proposed evidence failed the Mohan test for admissibility.
Specifically, the court held that the evidence lacked legal relevance as it was not grounded on proven facts and was unnecessary because the inferences sought by the Crown, such as interpreting text messages, did not require expert assistance.
