Gertner ruled in "U.S. v. Hines", 55 F.Supp. 2d 62 (D.Mass. 1999), a case regarding the admissibility of expert testimony, that (i) a handwriting expert could testify to similarities between handwriting samples but not state an opinion about whether the same person wrote both notes, and (ii) expert witness testimony regarding the reliability of eyewitness testimony, including problems of cross-racial identification, was admissible. The case interpreted new admissibility standards for expert testimony set forth by the Supreme Court in "Daubert v. Merrell Dow Pharmaceuticals", 509 U.S. 579 (1993) and "Kumho Tire Co. v. Carmichael", 526 U.S. 137 (1999).