Can a police officer testify as a lay witness about muzzle flashes?

The trial court concluded that the officer "probably does have sufficient knowledge, expertise and training in terms of being able to describe muzzle flashes and when they are fired away from him and when they are fired toward him"; but the court was "reluctant to overemphasize [the officer's] expertise" such that the jurors might view him as "a more credible witness . . . because he has been designated as an expert." Thus, the court ruled that the officer could testify as a lay witness but tell the jurors about his qualifications and experience concerning gunfire. Rejecting defense counsel's request to exclude it pursuant to Evidence Code section 352, the court found that the probative value of the opinion testimony outweighed any prejudice to defendant. The court later overruled defense counsel's objection that the officer's opinion testimony should be excluded pursuant to People v. Kelly (1976) 17 Cal.3d 24; the court explained: "[T]his is not the subject of a new scientific technique, nor is he testifying as an expert, but simply testifying as a percipient witness."