Holmes v. State
General statements from defense counsel are not sufficient to preserve error under T.R. Evid. 103(a)(2) when a trial court denies a defense motion to cross-examine a State's expert witness. The record must show the excluded evidence so that the appeals
court can judge its admissibility and determine whether the trial court
abused its discretion by excluding it. Counsel's statements do not
qualify as a reasonably specific summary of the evidence offered,
especially when the statements seem to question the underlying science
rather than the expert's credibility, and the complainant on appeal
deals with the expert's credibility.
