United States v. Paul, 175 F.3d 906 (11th Cir. 1999). · Go Syfert
United States v. Paul, 175 F.3d 906 (11th Cir. 1999). Cases Citing This Book View Copy Cite
124 citation events (107 in the last 25 years) across 37 distinct courts.
Strongest positive: United States v. Rodrick Maurice Hamilton (ca11, 2026-03-09) · Strongest negative: United States v. Fujii (ilnd, 2000-09-25)
Treatment trajectory · 1999 → 2026 · click a year to view as-of
1999 2012 2026
Top citers, strongest first. 50 distinct citers. How cited ↗
cited Cited "but see" United States v. Fujii
N.D. Ill. · 2000 · signal: but see · confidence high
But see United States v. Paul, 175 F.3d 906, 910-11 (11th Cir.), cert. denied, 528 U.S. 1023 , 120 S.Ct. 535 , 145 L.Ed.2d 415 (1999).
discussed Cited "but see" United States v. Van Wyk
D.N.J. · 2000 · signal: but see · confidence high
Ibid.; but see United States v. Paul, 175 F.3d 906, 911 (11th Cir.), cert. denied, — U.S. -, 120 S.Ct. 535 , 145 L.Ed.2d 415 (1999) (permitting handwriting expert to identify points of comparison between two writings and conclude that defendant was the author of both, but noting that jury was free to conduct own comparison and reach own conclusion regarding authorship of the unknown writing). i. Fitzgerald’s Opinion on Authorship of Writings The Court agrees with the rationale and approaches utilized in Hines, McVeigh, and Santillan .
examined Cited "but see" United States v. Hines (5×) also: Cited "see"
D. Mass. · 1999 · signal: but see · confidence high
Denbeaux's testimony was cited in United States v. Velasquez, 64 F.3d 844, 852 (3d Cir.1995) (concluding that the district court erred by refusing to allow defendant's expert document examiner to testify in response to the government’s document examiner); but see Paul, 175 F.3d 906, 911 (court did not err in excluding Denbeaux's rebuttal testimony). 16 .
cited Cited as authority (rule) United States v. Rodrick Maurice Hamilton
11th Cir. · 2026 · confidence medium
United States v. Paul, 175 F.3d 906, 912 (11th Cir. 1999).
cited Cited as authority (rule) Toussie v. Williams & Connolly, LLP
E.D.N.Y · 2025 · confidence medium
That itself is problematic.”) (citing United States v. Paul, 175 F.3d 906, 912 (11th Cir. 1999) and Trilink Saw Chain LLC v. Blount, Inc., 583 F. Supp. 2d 1293, 1304 (N.D.
cited Cited as authority (rule) Roberts v. Philadelphia Express Trust
S.D. Ga. · 2023 · confidence medium
Ga. Jan. 9, 2019) (Baker, J.) (citing United States v. Paul, 175 F.3d 906, 912 (11th Cir. 1999)).
discussed Cited as authority (rule) Smith v. The United States of America
S.D. Ga. · 2022 · confidence medium
Ga. Jan. 9, 2019) (Baker, J.) (citing United States v. Paul, 175 F.3d 906, 912 (11th Cir. 1999) (excluding law professor's handwriting analysis testimony, even though the professor had written on the topic, because his relevant expertise as a lawyer “did not make him any more qualified to testify as an expert on handwriting analysis than a lay person who read the same articles”)).
discussed Cited as authority (rule) Griffin v. Coffee County
S.D. Ga. · 2022 · confidence medium
United States v. Paul, 175 F.3d 906, 912 (11th Cir. 1999) (explaining an expert who lacks the relevant skills, experience, training, and education does not become qualified to testify as an expert merely because he read relevant articles).
cited Cited as authority (rule) United States v. Dorita Clay
11th Cir. · 2021 · confidence medium
United States v. Paul, 175 F.3d 906, 912 (11th Cir. 1999).
discussed Cited as authority (rule) In re Toy Asbestos Litigation
N.D. Cal. · 2021 · signal: cf. · confidence medium
Cal. 1982) (precluding witness from 18 testifying as expert regarding compilation of articles about the hazards of asbestos); cf. United 19 States v. Paul, 175 F.3d 906, 912 (11th Cir. 1999) (holding that absent some specific knowledge, 20 experience, or training, an individual’s review of articles does not make him any more qualified to 21 testify as an expert than a lay person who read the same articles).
discussed Cited as authority (rule) Murphy v. Richert
N.D. Ill. · 2019 · confidence medium
See United States v, Prime, 431 F.3d 1147, 1154 (9th Cir. 2005); United States v. Crisp, 324 F.3d 261, 269-70 (4th Cir. 2003); United States v. Mooney, 315 F.3d 54, 63 (1st Cir. 2002); United States v. Jolivet, 224 F.3d 902, 906 (8th Cir. 2000); United States v. Paul, 175 F.3d 906, 911 (11th Cir. 1999); United States v. Jones, 107 F.3d 1147, 1161 (6th Cir. 1997); United States v. Velasquez, 64 F.3d 844, 850-52 (3d Cir. 1995). 26(a)(2)(B)(iii) and 37(c)(1) and Federal Rules of Evidence 401(a), 702 and 1003 (PI.’s Mot. at 1; doc. # 314-1: Vastrick Report).
cited Cited as authority (rule) United States v. Romie Roland
11th Cir. · 2018 · confidence medium
United States v. Paul, 175 F.3d 906, 909 (11th Cir. 1999).
cited Cited as authority (rule) United States v. Azmat
11th Cir. · 2015 · confidence medium
United States v. Paul, 175 F.3d 906, 909 (11th Cir.1999).
cited Cited as authority (rule) United States v. Teresita Sorrels v. NCL (Bahamas), LTD
11th Cir. · 2015 · confidence medium
II “[We] review[ ] the district court’s decision to exclude expert testimony under Federal Rule of Evidence 702 for abuse of discretion.” United States v. Paul, 175 F.3d 906, 909 (11th Cir.1999).
discussed Cited as authority (rule) State of Arizona v. Joseph Javier Romero (2×)
Ariz. Ct. App. · 2014 · confidence medium
The expert “had no formal training as an accident investigator, had never attended a seminar on that subject, was not an aeronautical engineer, was not accredited as an instrument flight pilot, did not have a current pilot’s license, and had never flown a light aircraft similar to the one involved in this crash.” Id. ¶29 Similarly, in United States v. Paul, 175 F.3d 906, 912 (11th Cir.1999), the proponent sought to use an evidence law professor who had co-written an article critical of forensic document examiners to rebut the opinion of an expert in that field.
discussed Cited as authority (rule) United States v. Johnsted
W.D. Wis. · 2013 · confidence medium
See United States v. Prime, 431 F.3d 1147, 1152 (9th Cir.2005) (abuse of discretion); United States v. Crisp, 324 F.3d 261, 265 (4th Cir.2003) (abuse of discretion); United States v. Mooney, 315 F.3d 54, 62 (1st Cir.2002) (abuse of discretion); United States v. Jolivet, 224 F.3d 902, 906 (8th Cir.2000) (finding “no abuse of discretion, much less plain error”); United States v. Paul, 175 F.3d 906, 909 (11th Cir.1999) (abuse of discretion); United States v. Jones, 107 F.3d 1147, 1156 (6th Cir.1997) (applying abuse of discretion standard to expert’s case-specific testimony); United States v…
cited Cited as authority (rule) United States v. Carl Richard Samson
11th Cir. · 2013 · confidence medium
United States v. Paul, 175 F.3d 906, 912 (11th Cir. 1999).
cited Cited as authority (rule) United States v. Samson
11th Cir. · 2013 · confidence medium
United States v. Paul, 175 F.3d 906, 912 (11th Cir.1999).
cited Cited as authority (rule) M.D. v. Perry
S.D. Tex. · 2013 · confidence medium
Hr’g 1/23/13 (Berriek) at 51-52; (D.E. 173 at 6 (citing United States v. Paul, 175 F.3d 906, 912 (11th Cir.1999))).
discussed Cited as authority (rule) United States v. Yvonne Stouffrant
11th Cir. · 2013 · confidence medium
We review de novo the following pretrial and trial questions: whether the initial joinder of charges under Federal Rule of Criminal Procedure 8(a) was proper, United States v. Hersh, 297 F.3d 1233, 1241 (11th Cir.2002); interpretation of a rule of evidence, see United States v. Paul, 175 F.3d 906, 909 (11th Cir.1999) (“plenary review”); challenges to jury instructions, United States v. Bender, 290 F.3d 1279, 1284 (11th Cir.2002); whether an indictment has been constructively amended by jury instructions, see United States v. Sanders, 668 F.3d 1298 , 1309 n. 9 (11th Cir.2012); whether cumul…
discussed Cited as authority (rule) Lydia Rosenfeld v. Oceania Cruises, Inc. (2×)
11th Cir. · 2012 · confidence medium
For example, we have said that “when ‘[fjaeed with a proffer of expert scientific testimony ... the trial judge must determine at the outset’ ” such preliminary facts as “ “whether the expert is proposing to testify to (1) scientific knowledge that (2) will assist the trier of fact to understand or determine a fact in issue.’ ” United States v. Paul, 175 F.3d 906, 910 (11th Cir.1999) (alteration in original) (quoting Daubert v. Merrell Dow Pharm., Inc., 509 U.S. 579, 592 , 113 S.Ct. 2786, 2796 , 125 L.Ed.2d 469 (1993)).
discussed Cited as authority (rule) Lydia Rosenfeld v. Oceania Cruises, Inc.
11th Cir. · 2012 · confidence medium
For example, we have said that “when ‘[f]aced with a proffer of expert scientific testimony . . . the trial judge must determine at the outset’” such preliminary facts as “‘whether the expert is proposing to testify to (1) scientific knowledge that (2) will assist the trier of fact to understand or determine a fact in issue.’” United States v. Paul, 175 F.3d 906, 910 (11th Cir. 1999) (alteration in original) (quoting Daubert v. Merrell Dow Pharm., Inc., 509 U.S. 579, 592 , 113 S. Ct. 2786, 2796 , 125 L.
discussed Cited as authority (rule) United States v. McGarity (2×)
11th Cir. · 2012 · confidence medium
United, States v. Paul, 175 F.3d 906, 909 (11th Cir.1999).
discussed Cited as authority (rule) People v. Santana
Colo. · 2011 · confidence medium
See, eg., United States v. Diaz-Diaz, 433 F.3d 128, 135 (1st Cir.2005) (holding that even if prosecutor's possible burden-shifting remarks were error, any error was "immediately and effectively" addressed by "prompt and thorough" instructions to the jury); United States v. Paul, 175 F.3d 906, 912 (11th Cir.1999) (stating that to whatever degree the prosecutor's comments may have shifted the burden of proof, any prejudice was cured by the court's and counsel's instructions to the jury); Flowers v. State, 738 N.E.2d 1051, 1058-59 (Ind.2000) ("[PJrosecutor's comments during closing argument infer…
discussed Cited as authority (rule) United States v. Jamie Rogers
7th Cir. · 2011 · confidence medium
The government is allowed to defend its witnesses, see United States v. Nunez, 532 F.3d 645, 654 (7th Cir.2008); United States v. Johnson, 437 F.3d 665, 673-74 (7th Cir. 2006), and the prosecutor’s comments were fair responses to defense counsel’s attacks, see United States v. Young, 470 U.S. 1, 11-13 , 105 S.Ct. 1038 , 84 L.Ed.2d 1 (1985); United States v. Wimbley, 553 F.3d 455, 461 (6th Cir.2009); United States v. Paul, 175 F.3d 906, 912 (11th Cir.1999); United States v. Palmer, 37 F.3d 1080, 1086 (5th Cir.1994).
cited Cited as authority (rule) United States v. Michael Anthony
11th Cir. · 2009 · confidence medium
United States v. Paul, 175 F.3d 906, 909 (11th Cir.1999).
discussed Cited as authority (rule) United States v. Bryan Acosta
11th Cir. · 2009 · confidence medium
In any event, even if the prosecutor’s comment was impermissible, “the district court’s instruction on the burden of proof cured any prejudice.” United States v. Paul, 175 F.3d 906, 912 (11th Cir.1999).
discussed Cited as authority (rule) A v. by Versace, Inc. v. Gianni Versace S.P.A.
S.D.N.Y. · 2006 · confidence medium
See United States v. Prime, 431 F.3d 1147, 1151-54 (9th Cir.2005); United States v. Crisp, 324 F.3d 261, 271 (4th Cir.2003); United States v. Mooney, 315 F.3d 54, 61-63 (1st Cir.2002); United States v. Jolivet, 224 F.3d 902, 905-06 (8th Cir.2000); United States v. Paul, 175 F.3d 906, 909-12 (11th Cir.1999); United States v. Jones, 107 F.3d 1147, 1161 (6th Cir.1997); United States v. Velasquez, 64 F.3d 844, 850-52 (3d Cir.1995). 15 .
discussed Cited as authority (rule) Dracz v. American General Life Insurance (2×) also: Cited "see, e.g."
M.D. Ga. · 2006 · confidence medium
Plaintiff contends that Mr. Baggett is sufficiently qualified because (1) according to his expert report, he has twenty-two years of experience in the field of document exami *1378 nation; 12 (2) he received ten years of training and supervision in the field of handwriting analysis and document examination from Dr. Ray Walker; 13 (3) he received document examination training from the United States Army in 1960; 14 and (4) he served as a document examination consultant to a Dallas, Texas Justice of the Peace Court in 1991-92 and the Dallas County District Attorney’s Office in 1991. 15 Plainti…
discussed Cited as authority (rule) United States v. Prime
9th Cir. · 2005 · confidence medium
See United States v. Crisp, 324 F.3d 261, 269-70 (4th Cir. 2003); United States v. Mooney, 315 F.3d 54, 63 (1st Cir. 2002); United States v. Jolivet, 224 F.3d 902, 906 (8th Cir. 2000); United States v. Paul, 175 F.3d 906, 911 (11th Cir. UNITED STATES v. PRIME 16311 1999); United States v. Jones, 107 F.3d 1147, 1161 (6th Cir. 1997); United States v. Velasquez, 64 F.3d 844, 850-52 (3d Cir. 1995).
examined Cited as authority (rule) United States v. Richard Junior Frazier (6×) also: Cited "see, e.g."
11th Cir. · 2004 · confidence medium
Corp. v. Benfield, 140 F.3d 915, 921 (11th Cir.1998) (“It is very much a matter of discretion with the trial court whether to permit the introduction of [expert] evidence, and we will not reverse the decision of the trial court regarding the exclusion or admission of such evidence unless the trial court’s decision is ‘manifestly erroneous.’ ”); see also Toole v. Baxter Healthcare Corp., 235 F.3d 1307, 1312 (11th Cir.2000) (“We review a trial court’s evidentiary rulings on the admission of expert witness testimony for abuse of discretion.”); United States v. Paul, 175 F.3d 906, …
discussed Cited as authority (rule) United States v. Michael Stefan Prime
9th Cir. · 2004 · confidence medium
See United States v. Crisp, 324 F.3d 261, 269-70 (4th Cir.2003); United States v. Mooney, 315 F.3d 54, 63 (1st Cir.2002); United States v. Jolivet, 224 F.3d 902, 906 (8th Cir.2000); United *1035 States v. Paul, 175 F.3d 906, 911 (11th Cir.1999); United States v. Jones, 107 F.3d 1147, 1161 (6th Cir.1997); United States v. Velasquez, 64 F.3d 844, 850-52 (3d Cir.1995).
discussed Cited as authority (rule) United States v. Prime
9th Cir. · 2004 · confidence medium
See United States v. Crisp, 324 F.3d 261, 269-70 (4th Cir.2003); United States v. Mooney, 315 F.3d 54, 63 (1st Cir.2002); United States v. Jolivet, 224 F.3d 902, 906 (8th Cir.2000); United States v. Paul, 175 F.3d 906, 911 (11th Cir.1999); United States v. Jones, 107 F.3d 1147, 1161 (6th Cir.1997); United States v. Velasquez, 64 F.3d 844, 850-52 (3d Cir.1995).
discussed Cited as authority (rule) Commonwealth v. Glyman
Mass. Super. Ct. · 2003 · confidence medium
See United States v. Crisp, 324 F.3d 261, 270-71 (4th Cir. 2003); United States v. Mooney, 315 F.3d 54, 62-63 (1st Cir. 2002); United States v. Jolivet, 224 F.3d 902, 905-06 (8th Cir. 2000); United States v. Paul 175 F.3d 906, 909-11 (11th Cir. 1999); United States v. Jones, 107 F.3d 1147, 1156-60 (6th Cir. 1997); United States v. Velasquez, 64 F.3d 844, 848-50 (3d Cir. 1995).
discussed Cited as authority (rule) Deputy, Doris v. Lehman Brothers Inc
7th Cir. · 2003 · confidence medium
United States v. Crisp, 324 F.3d 261, 270 (4th Cir. 2003); United States v. Jolivet, 224 F.3d 902, 906 (8th Cir. 2000); United States v. Paul, 175 F.3d 906, 911 (11th Cir. 1999); United States v. Jones, 107 F.3d 1147, 1161 (6th Cir. 1997); United States v. Velasquez, 64 F.3d 844, 848-49 (3d Cir. 1995).
discussed Cited as authority (rule) Doris Deputy v. Lehman Brothers, Inc.
7th Cir. · 2003 · confidence medium
United States v. Crisp, 324 F.3d 261, 270 (4th Cir.2003); United States v. Jolivet, 224 F.3d 902, 906 (8th Cir.2000); United States v. Paul, 175 F.3d 906, 911 (11th Cir.1999); United States v. Jones, 107 F.3d 1147, 1161 (6th Cir.1997); United States v. Velasquez, 64 F.3d 844 , 848-49 (3d Cir.1995).
discussed Cited as authority (rule) United States v. Patrick Leroy Crisp (2×)
4th Cir. · 2003 · confidence medium
See United States v. Jolivet, 224 F.3d 902, 906 (8th Cir.2000) (citing Eleventh Circuit’s Paul decision and upholding admission of expert handwriting testimony); United States v. Paul, 175 F.3d 906, 911 (11th Cir.1999) (emphasizing “flexible” nature of district court’s gatek-eeping function, and noting that “the ability of the jury to perform the same visual comparisons as the experts cuts against the danger of undue prejudice from the mystique attached to experts” (internal quotation omitted)); United States v. Jones, 107 F.3d 1147, 1161 (6th Cir.1997) (upholding admission of expe…
discussed Cited as authority (rule) United States v. Crisp
4th Cir. · 2003 · confidence medium
See United States v. Jolivet, 224 F.3d 902, 906 (8th Cir. 2000) (citing Eleventh Circuit’s Paul decision and upholding admission of expert handwriting testimony); United States v. Paul, 175 F.3d 906, 911 (11th Cir. 1999) (emphasizing "flexible" nature of district court’s gatekeeping function, and noting that "the ability of the jury to per- form the same visual comparisons as the experts cuts against the dan- ger of undue prejudice from the mystique attached to experts" (internal quotation omitted)); United States v. Jones, 107 F.3d 1147, 1161 (6th Cir. 1997) (upholding admission of expert…
discussed Cited as authority (rule) United States v. Richard Junior Frazier (2×)
11th Cir. · 2003 · confidence medium
United States v. Paul, 175 F.3d 906, 909 (11th Cir.1999).
discussed Cited as authority (rule) Newton v. Roche Laboratories, Inc.
W.D. Tex. · 2002 · confidence medium
As one Court of Appeals has put it, an individual’s “review of literature” in an area outside his field does “not make him any more qualified to testify as an expert ... than a lay person who read the same articles.” United States v. Paul, 175 F.3d 906, 912 (11th Cir.1999).
discussed Cited as authority (rule) United States v. Prime
W.D. Wash. · 2002 · confidence medium
See, e.g., United States v. Jolivet, 224 F.3d 902, 906 (8th Cir.2000) (upholding district court’s decision to admit testimony of handwriting comparison expert); United States v. Hernandez, 42 Fed.Appx. 173 (10th Cir.2002) (upholding district court’s decision to allow testimony on similarities and differences, but disallowing testimony on conclusions) (unpublished disposition); United States v. Paul, 175 F.3d 906, 912 (11th Cir.1999) (upholding district court’s decision to exclude testimony of law professor critical of forensic document examination).
discussed Cited as authority (rule) United States v. Lewis (2×) also: Cited "see, e.g."
S.D.W. Va · 2002 · confidence medium
See, e.g., United States v. Jolivet, 224 F.3d 902, 905-06 (8th Cir.2000) (affirming under plain error review the district judge’s decision to admit handwriting expert’s testimony without applying Daubert factors); United States v. Paul, 175 F.3d 906, 910-11 (11th Cir.1999) (concluding summarily that Daubert factors do not necessarily apply to admission of handwriting expert, but failing to address any alternative measures of reliability); United States v. Velasquez, 64 F.3d 844, 849-50 (3d Cir.1995) (cautioning against strict application of the reliability requirement and finding that the …
discussed Cited as authority (rule) United States v. Hernandez
10th Cir. · 2002 · confidence medium
For post-Daubert cases upholding the admission of "opinion” testimony of an expert handwriting witness as to the defendant's authorship of a questioned document, see United States v. Jolivet, 224 F.3d 902, 905-06 (8th Cir.2000), United States v. Paul, 175 F.3d 906, 909-11 (11th Cir.), cert. denied, 528 U.S. 1023 , 120 S.Ct. 535 , 145 L.Ed.2d 415 (1999), and United States v. Velasquez, 64 F.3d 844, 848-50 (3rd Cir.1995). .
cited Cited "see" United States v. Julio Estrada
11th Cir. · 2020 · signal: see · confidence high
See United States v. Paul, 175 F.3d 906, 909 (11th Cir. 1999).
discussed Cited "see" United States v. Laura Grande-Signore
11th Cir. · 2019 · signal: see · confidence high
Lopez, 590 F.3d at 1256 ; see United States v. Paul, 175 F.3d 906, 912 (11th Cir. 1999) (no prejudice to substantial rights when government only pointed out that defendant had opportunity to present evidence, lawyers and court reminded jury that government had burden of proof, and district court gave instruction on burden of proof); United States v. Bailey, 123 F.3d 1381, 1402 (11th Cir. 1997) (any possible prejudice resulting from prosecutor’s closing argument cured by instructions that lawyers’ arguments are not evidence and jury is to decide case solely on evidence presented at trial).
cited Cited "see" United States v. Lee Ervin Dale
11th Cir. · 2015 · signal: see · confidence high
See United States v. Paul, 175 F.3d 906 , 909-10 & n. 2 (11th Cir.1999) (finding that the argument that “handwriting analysis does not qualify as reliable scientific evidence” is meritless).
discussed Cited "see" Cordoves v. Miami-Dade County
S.D. Fla. · 2015 · signal: see · confidence high
See United States v. Paul, 175 F.3d 906, 911 (11th Cir.1999) (finding expert qualified even though “no licensing board existed for questioned documents examiners, and the profession is not subject to standards that quantify or .measure the work of individual examiners”).
discussed Cited "see" Miller v. State (2×)
Md. · 2011 · signal: see · confidence high
See United States v. Paul, 175 F.3d 906, 910-11 (11th Cir.1999).
cited Cited "see" United States v. Taylor
D.N.M. · 2009 · signal: see · confidence high
See id. at 911-12 .
cited Cited "see" United States v. Ellis Jerome Parker, Sr.
11th Cir. · 2008 · signal: see · confidence high
See United States v. Paul, 175 F.3d 906, 912 (11th Cir.1999).
Retrieving the full opinion text from the archive…
UNITED STATES of America, Plaintiff-Appellee,
v.
Sunonda G. PAUL, Defendant-Appellant
97-9302.
Court of Appeals for the Eleventh Circuit.
May 13, 1999.
175 F.3d 906
Suzanne Hashimi, Federal Defender Program, Inc., Atlanta, GA, for Defendant-Appellant., Janet King, Bryan J. Farrell, Assistant U.S. Attorney, Amy Weil, Assistant U.S. Attorney, William L. McKinnon, Jr., Assistant U.S. Attorney, Atlanta, GA, for Plaintiff-Appellee.
Hatchett, Hull, Moore.
Cited by 78 opinions  |  Published
HATCHETT, Chief Judge:

Appellant Sunonda Paul appeals the district court’s (1) finding that a government witness was qualified to testify as a handwriting expert, (2) refusal to admit his handwriting expert’s rebuttal testimony and (3) failure to declare a mistrial due to the prosecutor’s improper remarks. We affirm.

I. FACTS

In May 1996, an unidentified person who stated that he was a bank investigator telephoned Ed Spearman, branch manager of Wachovia National Bank (Wachovia) at Atlanta, Georgia, and warned him that someone intended to leave a note at the bank in an attempt to extort money from the bank. The “investigator” instructed Spearman to follow the directions in the note. Spearman contacted bank security and the Federal Bureau of Investigation (FBI), who advised him to contact the agency immediately if he received an extortion demand. On the following morning, a security camera outside the entrance to Wachovia Bank videotaped a man, wearing a scarf and sunglasses, place an envelope under the front door of the bank. Inside the envelope, addressed to Spear-man, was an extortion note that directed Spearman to deliver $100,000 to the men’s restroom of a downtown Atlanta McDonald’s restaurant. The note threatened violence if Spearman did not follow the instructions and make the payment. Spearman notified bank security and the FBI.

The investigating agents developed a plan to arrest the extortionist: an FBI agent, acting as Spearman, would drive Spearman’s car to the McDonald’s and place a briefcase in the men’s restroom, while surveillance agents would watch the restroom and arrest the person who took the briefcase.

In executing the plan, FBI Agent Eric Bryant testified that upon his arrival at the McDonald’s, he entered the men’s restroom, observed appellant Sunonda Paul in a restroom stall, left a briefcase and exited the restroom. FBI surveillance agents testified that they later saw Paul sitting at a table near the restroom. As Bryant left the McDonald’s, surveillance agents observed Paul enter the restroom again and then attempt to leave the establishment with the briefcase in his backpack. When confronted, Paul told the agents that he was in the area to visit a nearby gym and had stopped at the McDonald’s for breakfast. He also told them that he decided to take the briefcase after he found it in the restroom. Paul, however, was dressed in casual street clothing and had no gym clothes or athletic equipment in his possession. The agents arrested him.

II. PROCEDURAL HISTORY

A grand jury indicted Paul on one count of bank extortion, in violation of 18 U.S.C. § 2113(a), and Paul pleaded not guilty. Prior to trial, Paul moved in limine to exclude FBI document examiner Larry Ziegler’s testimony regarding handwriting analysis. The district court, however, denied Paul’s motion at the pretrial hearing.

The demand note left at Wachovia was the key evidence in determining whether Paul was the extortionist. Although FBI agents examined the videotape to determine the identity of the person who deliv[*909] ered the note, they could not identify the person conclusively. Consequently, the FBI conducted fingerprint and handwriting analysis tests on the note to establish the identity of the extortionist. A fingerprint expert concluded that the latent prints on the note and envelope did not match Paul’s fingerprints.

Ziegler, the FBI document examiner, compared the handwriting on the note and the envelope to Paul’s handwriting samples and concluded that Paul was the author of both. Specifically, Ziegler asked Paul to write the word restaurant. In the presence of an FBI agent, Paul misspelled the word as follows: “resturant.” In the extortion note the extortionist misspelled the word restaurant the same way. Ziegler also asked Paul to write out “Spearman.” Paul spelled it “Sperman,” the same way the extortionist had addressed the envelope.

In June 1997, a jury could not reach a unanimous verdict; therefore, the court declared a mistrial. On August 6, 1997, at the retrial, the district court orally granted the government’s motion in limine to exclude the testimony of Mark Denbeaux, a law professor, pursuant to Federal Rule of Evidence 702 because the district court thought his testimony would be confusing to the jury. [1] The court also denied Paul’s renewed motion to exclude Ziegler’s testimony regarding handwriting analysis. The second jury found Paul guilty of extortion, in violation of 18 U.S.C. § 2118(a), and the district court sentenced Paul to 68 months imprisonment, with a 3-year term of supervised release.

III. ISSUES .

The issues we discuss are whether: (1) the district court abused its discretion in qualifying Ziegler as an expert and allowing the government to present handwriting analysis evidence; (2) the district court abused its discretion in excluding Den-beaux’s rebuttal testimony; and (3) the prosecutor’s closing argument improperly shifted the burden of proof to Paul.

IV. STANDARD OF REVIEW

This,,court reviews the district court’s decision to exclude expert testimony under Federal Rule of Evidence 702 for abuse of discretion. General Electric Co. v. Joiner, 522 U.S. 136, 139, 118 S.Ct. 512, 139 L.Ed.2d 508 (1997); United States v. Gilliard, 133 F.3d 809 (11th Cir.1998). To the extent that a ruling of the district court turns on an interpretation of a Federal Rule of Evidence, our review is plenary. Daubert v. Merrell Dow Pharmaceuticals, Inc., 509 U.S. 579, 113 S.Ct. 2786, 125 L.Ed.2d 469 (1993). As to expert testimony, however, we review for abuse of discretion. See General Electric, 522 U.S. at 139, 118 S.Ct. 512. In reviewing a claim of prosecutorial misconduct, we assess (1) whether the challenged comments were improper and (2) if so, whether they prejudiced the defendant’s substantial rights. United States v. Delgado, 56 F.3d 1357, 1368 (11th Cir.1995).

V. DISCUSSION

A. Ziegler’s Testimony

Paul contends that the district court abused its discretion in admitting Ziegler’s testimony as an expert document examiner because: (1) his handwriting analysis failed to meet the reliability requirements of Daubert; (2) Ziegler’s testimony did not assist the trier of fact; and (3) Ziegler’s testimony was more prejudicial than probative under Federal Rules of Evidence 403.

1. Admissibility of Handwriting Analysis

Paul argues that Ziegler's testimony is not admissible under the Daubert guide[*910] lines because handwriting analysis does not qualify as reliable scientific evidence. His argument is without merit. [2] In Dau-bert, the Supreme Court held that Federal Rule of Evidence 702 controls decisions regarding the admissibility of expert testimony. [3] The Supreme Court declared that under rule 702, when “[fjaced with a proffer of expert scientific testimony ... the trial judge must determine at the outset pursuant to Rule 104(a), whether the expert is proposing to testify to (1) scientific knowledge that (2) will assist the trier of fact to understand or determine a fact in issue.” Daubert, 509 U.S. at 592, 113 S.Ct. 2786. The Supreme Court stated that “[t]he inquiry envisioned by Rule 702 is, we emphasize, a flexible one” and that “Rule 702 ... assign[s] to the trial judge the task of ensuring that an expert’s testimony both rests on a reliable foundation and is relevant to the task at hand.” Daubert, 509 U.S. at 594, 597, 113 S.Ct. 2786. The Court also listed several factors to assist in the determination of whether evidence is scientifically reliable. [4] See Daubert, 509 U.S. 592-95, 113 S.Ct. 2786.

Many circuits were split at the time of trial, however, on whether Daubert should apply to nonscientifie expert testimony. Some held that the application of Daubert is limited to scientific testimony, while others used Daubert’s guidance to ensure the reliability of all expert testimony presented at trial. Compare McKendall v. Crown Control Corp., 122 F.3d 803 (9th Cir.1997) (limiting the application of Daubert to the evaluation of scientific testimony); with Watkins v. Telsmith, Inc., 121 F.3d 984 (5th Cir.1997) (holding that the application of Daubert is not limited to scientific knowledge).

Recently, however, in Kumho Tire Company, Ltd. v. Carmichael, the Supreme Court held that Daubert’s “gatekeeping” obligation, requiring the trial judge’s inquiry into both the expert’s relevance and reliability, applies not only to testimony based on “scientific” testimony, but to all expert testimony. Kumho, — U.S.—, —, 119 S.Ct. 1167, 1174, 143 L.Ed.2d 238 (1999). The Court further noted that rules 702 and 703 give all expert witnesses testimonial leeway unavailable to other witnesses on the presumption that the expert’s opinion “will have a rehable basis in the knowledge and experience of his discipline.” Kumho, — U.S. at —, 119 S.Ct. at 1174 (citing Daubert, 509 U.S. at 592, 113 S.Ct. 2786). Moreover, the Court held that a trial judge may consider one or more of the specific Daubert factors when doing so will help determine that expert’s reliability. Kumho, — U.S. at—, 119 S.Ct. at 1175. But, as the Court stated in Daubert, the test of reliability is a “flexible” one, and Daubert’s list of specific factors neither necessarily nor solely applies to all experts or in every case. Kumho, — U.S. at —, 119 S.Ct. at 1175 (citing Daubert, 509 U.S. at 594, 113 S.Ct. 2786). Alternatively, Kumho declares that “the law grants a district court the same broad latitude when it decides how to determine reliability as it enjoys in respect to its ultimate reliability determination.”[*911] Kumho, — U.S. at—, 119 S.Ct. at 1171 (citing General Electric Co. v. Joiner, 522 U.S. 136, 148, 118 S.Ct. 512, 139 L.Ed.2d 508 (1997) (stating that courts of appeals are to apply “abuse of discretion” standard when reviewing district court’s reliability determination)).

2. Testimony Assists Trier of Fact

Paul also asserts that Ziegler’s testimony was inadmissible because it did not assist the jury’s understanding of the evidence. Properly qualified expert witnesses may testify regarding their specialized knowledge in a given field if it “would assist the trier of fact to understand the evidence or to determine a fact in issue.” Fed.R.Evid. 702; see also United States v. Rouco, 765 F.2d 983, 995 (11th Cir.1985) (arguing that counsel may use an expert if the expert’s testimony can offer something “beyond the understanding and experience of the average citizen”), cert. denied, 475 U.S. 1124, 106 S.Ct. 1646, 90 L.Ed.2d 190 (1986); United States v. Burchfield, 719 F.2d 356 (11th Cir.1983) (explaining that expert testimony is admissible where it is “the kind that enlightens and informs lay persons without expertise in a specialized field”).

Paul has not challenged on appeal Ziegler’s qualifications as an expert on handwriting analysis. In fact, at the time of the trial, Ziegler: (1) was a full time handwriting examiner for 30 years; (2) was a member of four professional handwriting analysis organizations; (3) established both the Secret Service’s and the Naval Investigative Service’s “questioned document” laboratories; (4) lectured and taught extensively in the field of handwriting analysis; and (5) trained new “questioned document” examiners for several law enforcement organizations. Consequently, we hold that Ziegler’s expert testimony could assist the jury.

S. Testimony More Probative than Prejudicial

Paul asserts that the district court should have excluded Ziegler’s testimony under Federal Rule of Evidence 403 as prejudicial because he claims the jury would have believed that Ziegler’s analysis was scientific when it was not. [5] Paul, however, cites no authority excluding testimony from an expert handwriting examiner on the basis that it sounded scientific, but was not. To the contrary, the Sixth Circuit in United States v. Jones concluded that the ability of the jury to perform the same visual comparisons as the expert “cuts against the danger of undue prejudice from the mystique attached to ‘experts.’ ” 107 F.3d 1147, 1160-61 (6th Cir.1997). As was true in Jones, Ziegler specifically identified points of comparison that he recognized between the writing of the extortion note and the handwriting examples that Paul provided. The jury was free to conduct its own comparison and reach its own conclusion regarding the author of the extortion note.

Moreover, Ziegler acknowledged on cross-examination that no licensing board existed for questioned documents examiners, and the profession is not subject to standards that quantify or measure the work of individual examiners. Given Ziegler’s admissions, the jury would not have been confused whether handwriting analysis is scientific or is unassailable. Therefore, this court cannot conclude that Ziegler’s qualifications prejudiced Paul. Consequently, we hold that the district court did not err in admitting Ziegler’s testimony.

B. Denbeaux’s Testimony

Paul argues that the district court abused its discretion in not admitting Denbeaux’s rebuttal testimony. Specifi[*912] cally, Paul contends that if Ziegler’s testimony was admissible under rule 702, then Denbeaux’s testimony was also admissible pursuant to rule 702 because Denbeaux’s testimony was critical for the jury to understand the limitations of Ziegler’s testimony.

The government asserts two grounds for excluding Denbeaux’s testimony: (1) Paul cannot show that Denbeaux was an expert on handwriting analysis; and (2) the court’s exclusion of Denbeaux’s testimony did not prejudice Paul.

Denbeaux was not qualified to testify as an expert in handwriting analysis because he: (1) did not possess an acceptable degree of “knowledge”; (2) would not have assisted the jury; and (3) was not a qualified expert. Fed.R.Evid. 702. The record reflects that Denbeaux had no skill, experience, training or education in the field of handwriting analysis. The record shows that Denbeaux has a law degree and that he is a law professor who teaches evidence. Before 1989, he reviewed the literature in the field of questioned document examinations, and then coauthored a law review article critical of forensic document examiners’ ability to reach the correct conclusion in questioned document examinations. See D. Michael Risinger, Mark Denbeaux and Michael J. Saks, Exorcism, of Ignorance as a Proxy for Rational Knowledge: The Lessons of Handwriting Identification Expertise, 137 U. Pa. L.Rev. 731 (1989). His skill, experience, training and education as a lawyer did not make him any more qualified to testify as an expert on handwriting analysis than a lay person who read the same articles.

At the time of the trial, Denbeaux had done virtually no further research or writing on the subject of the reliability of handwriting expertise since the University of Pennsylvania published his law review article in 1989. During cross-examination, he admitted that he was not a questioned documents examiner, had received no formal training in the field, had never attended seminars on handwriting analysis, had never worked in a questioned documents laboratory and was not a member of any professional organizations in the field. Further, because Denbeaux was not an expert on the limitations of handwriting analysis, the district court’s exclusion of his testimony did not prejudice Paul. Den-beaux’s background did not qualify him as an expert, and his knowledge of the subject matter is so limited that it was not an abuse of discretion for the district court to exclude his testimony under rule 702. See Fed.R.Evid. 702.

C. Prosecutorial Misconduct

Paul asserts that the prosecutor’s closing argument was improper and unlawfully shifted the burden of proof. “Prosecutorial misconduct requires a new trial only if [the court] find[s] the remarks (1) were improper and (2) prejudiced the defendants’ substantive rights.” United States v. Delgado, 56 F.3d 1357, 1368 (11th Cir.1995) (citing United States v. Cole, 755 F.2d 748, 767 (11th Cir.1985)).

In his closing argument, the prosecutor stated: “Remember[J the defense has the resources and has the opportunity to produce evidence themselves, as you saw the defendant do.” Paul’s lawyer objected and the court overruled the objection stating, “He [the government] didn’t say you had a burden as I understood him. He merely said opportunity.”

The government’s statement did not prejudice Paul’s substantive rights in shifting the burden of proof. The government told the jury that Paul had the opportunity to produce a handwriting expert to rebut Ziegler’s testimony — -not that Paul had any burden to produce a rebuttal expert. Additionally, the prosecutor, Paul’s lawyer and the court repeatedly reminded the jury that the government bore the burden of proof. Furthermore, the district court’s instruction on the burden of proof cured any prejudice. See Duncan v. Stynchcombe, 704 F.2d 1213, 1216 (11th Cir.1983).

[*913] VI. CONCLUSION

For the foregoing reasons, we affirm the judgment of the district court.

AFFIRMED.

1

. The district court noted that it had been willing to exclude Denbeaux's testimony from the first trial, but the court allowed it when the Assistant United States Attorney who initially tried the case asked that the court admit the testimony.

2

. Courts have long received handwriting analysis testimony as admissible evidence. See United States v. Jones, 107 F.3d 1147, 1160-61 (6th Cir.1997) (handwriting expert's testimony admissible to show that signatures on numerous documents were defendant's); United States v. Velasquez, 64 F.3d 844, 848-50 (3d Cir.1995) (handwriting expert witness admissible).

3

. Federal Rule of Evidence 702 provides: “If scientific, technical or other specialized knowledge will assist the court to understand the evidence or to determine a fact in issue, a witness qualified as an expert by knowledge, skill, experience, training, or education, may testify thereto in the form of an opinion or otherwise.” Fed.R.Evid. 702.

4

.The Daubert factors include: (1) whether the theory or technique the expert employs is generally accepted in the scientific community; (2) whether the theory has been subject to peer review and publication; (3) whether the theory can and has been tested; and (4) whether the known or potential rate of error is acceptable. Daubert, 509 U.S. at 592-95, 113 S.Ct. 2786.

5

. Federal Rule of Evidence 403 provides: "Although relevant, evidence may be excluded if its probative value is substantially outweighed by the danger of unfair prejudice, confusion of the issues, or misleading the jury, or by considerations of undue delay, waste of time, or needless presentation of cumulative evidence." Fed.R.Evid. 403.