California, United States of America
The following excerpt is from People v. Stephan, F069658 (Cal. App. 2017):
"Evidence Code section 720 provides that a person may testify as an expert 'if he [or she] has special knowledge, skill, experience, training, or education sufficient to qualify him,' [citation] which 'may be shown by any otherwise admissible evidence, including his own testimony.' [Citation.] The trial court's determination of whether a witness qualifies as an expert is a matter of discretion and will not be disturbed absent a showing of manifest abuse. [Citation.]" (People v. Bolin (1998) 18 Cal.4th 297, 321-322.)
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