Defendant Bryant Wilson (hereinafter “Defendant”) was charged with voluntary manslaughter and possession of contraband in prison, following a prison fight at USP Canaan that resulted in the stabbing death of Defendant’s victim on November 28, 2021.
Defendant did not contest that the fight happened, nor that the death of his victim resulted; rather, he asserted that he acted in self-defense.
On November 10, 2025, Defendant notified the Government that he wished to offer the expert testimony of Dr. Stephen M. Timchack, PsyD at trial, pursuant to Rule 702 of the Federal Rules of Evidence. He indicated that Timchak would testify to Defendant’s symptoms consistent with Post Traumatic Stress Disorder (“PTSD”).
Psychology Expert Witness
Dr. Stephen M. Timchack, PsyD has extensive training and background in both clinical and forensic psychology.
Timchack has held faculty positions at Wilkes University, Misericordia University, and the University of Scranton.
Discussion by the Court
Psychiatric evidence cannot serve as a defense unless it renders the Defendant legally insane, and even if the Defendant is deemed insane, such evidence is inadmissible unless it negates the mens rea of the crime charged.
Here, the Government thoroughly analyzed this issue with respect to the mens rea requirement of voluntary manslaughter.
Defendant did not dispute the Government’s argument; instead, Defendant narrowly focused on admissibility of the psychiatric evidence for purposes of his self-defense claim. Thus, Defendant essentially conceded that his PTSD evidence did not truly negate mens rea.
The PTSD evidence did not negate mens rea, so it was inadmissible. Furthermore, Defendant’s analogous reasoning did not hold up under scrutiny. As the Government noted,
“Battered woman’s syndrome focuses on the perceived threat posed by the batterer on the battered, while PTSD, as shown by Timchak’s report, focuses on a more general, perceptual perceived threat posed to the PTSD-sufferer by his surroundings . . . Here, [Defendant] was not under duress or defending himself against his “batterer” or someone who had assaulted him in the past. So [Defendant’s] PTSD is much less probative to the disputed issues here than those in the cases relied on by the Defendant.”
Even if the Court were to find that PTSD negates the mens rea of voluntary manslaughter in this case, the psychiatric evidence would still be inadmissible as both irrelevant and confusing to the jury.
Held
The Court granted the Government’s motion in limine to preclude the expert testimony of Dr. Stephen Timchak.
Key Takeaway:
Simply, PTSD does not constitute insanity, nor does PTSD negate the mens rea for voluntary manslaughter. The Court posits, as a theory, that PTSD could have inflamed Defendant’s reaction such that he carried out the killing in the heat of passion. In other words, PTSD likely offers an explanation, not a negation.
Case Details:
| Case Caption: | USA V. Wilson |
| Docket Number: | 3:24cr239 |
| Court Name: | United States District Court, Pennsylvania Middle |
| Order Date: | November 17, 2025 |
Please refer to the blog previously published about this case:
Prison Expert Was Not Allowed to Opine on Proper Staff Procedure
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