Arrays Ballard first argues that his due process rights were violated due to the spoliation of evidence of possible suggestive identification procedures and that, as a result, the evidence of the identifications at trial should have been suppressed. As we set forth in Raheem v. Kelly, 257 F.3d 122 (2d Cir.2001), “[d]ue process requires that criminal trials proceed consistently with that fundamental fairness which is essential to the very concept of justice. When the prosecution offers testimony from an eyewitness to identify the defendant as a perpetrator of the offense, fundamental fairness requires that that identification testimony be reliable.” Id. at 133 (internal quotation marks and citations omitted); see also Manson v. Brathwaite, 432 U.S. 98, 114, 97 S.Ct. 2243, 53 L.Ed.2d 140 (<HOLDING>); Watkins v. Sowders, 449 U.S. 341, 347, 101
holding experts experience knowledge and training is considered in determining reliability holding that the admissibility of lay witness identification testimony turns on a number of factors holding that reliability is the linchpin in determining the admissibility of identification testimony holding that the admissibility of expert testimony was governed by state law holding that trial courts are gatekeepers in determining fitness of scientific expert testimony for admissibility at trial