and developments.” Model Code of Prof'l Responsibility EC 6-2 (1980); see also Strickland, 466 U.S. at 688, 104 S.Ct. 2052 (“Prevailing norms of practice as reflected in American Bar Association standards ... [are] ‘guides to determining what is reasonable.’ ”) Popular legal casebooks, such as David L. Faigman et al., Science in the Law: Forensic Science Issues (2002), highlighted problems in many cause-and-origin techniques. In addition, in the early 2000s, several reports and articles were published that impugned arson investigatory techñiques as well as forensic evidence more ge e of discretion where trial court excluded arson expert’s testimony because his methodology did not support his conclusion); Ind. Ins. Co. v. Gen. Elec. Co., 326 F.Supp.2d 844, 850-51 (N.D.Ohio 2004) (<HOLDING>); Am. Family Ins. Grp. v. JVC Am. Corp., No.
holding that causeandorigin ex perts failure to properly collect evidence in violation of nfpa 921 section 951 documenting the collection of physical evidence made his investigation unreliable holding that testimony of two experts was unreliable because they relied on the testimony of two other experts which was also unreliable holding that eauseandorigin experts failure to properly collect evidence in violation of the section of nfpa 921 entitled documenting the collection of physical evidence made his investigation unreliable holding district courts exclusion of expert arson evidence proper where experts failed to compare hypothesis to evidence from scene in violation of nfpa 921 holding that other evidence properly admitted at trial was sufficiently strong to permit the conclusion that the improper admission of unreliable expert testimony was harmless