This case arises out of the tragic murder of four University of Idaho students in November 2022. Plaintiff Rebecca Scofield is a professor at the University of Idaho. She alleged that, despite never meeting any of these students or being involved with their murders in any way, Defendant Ashley Guillard posted numerous TikTok (and later YouTube) videos falsely claiming that Plaintiff (i) had an extramarital, same-sex, romantic affair with one of the victims; and then (ii) ordered the four murders to prevent the affair from coming to light.
Plaintiff sent cease-and-desist letters to Defendant in the following days and weeks. When Defendant did not stop, Plaintiff initiated this action. Plaintiff asserts two defamation claims against Defendant: one is premised upon the false statements regarding Plaintiff’s involvement with the murders themselves, the other is premised upon the false statement regarding Plaintiff’s romantic relationship with one of the murdered students.
Plaintiff has identified two experts who may testify at trial: Dr. Rebecca Tallent and Rebecca Bohn. In advance of trial, Defendant filed a motion to exclude these experts’ testimony pursuant to Federal Rule of Evidence 702.
Public Relations Expert Witness
Rebecca J. Tallent is a retired associate professor emerita with more than five decades of experience in journalism, public relations, and academia. She holds a bachelor’s degree in journalism, a master’s degree in education with a journalism emphasis, and a doctorate in education focused on higher education, classroom teaching, and mass communications.
During her career, Tallent taught public relations and journalism at the University of Idaho and other institutions, published scholarly and professional works on media and ethics, and worked professionally in journalism and public relations.
Mental Health Expert Witness
Rebecca Bohn is a licensed mental health counselor with a Master of Arts degree in counseling psychology and more than three decades of experience providing psychotherapy and behavioral health treatment.
Discussion by the Court
Rebecca Tallent
Tallent offered opinions concerning how defamatory statements made via social medial can affect an individual’s professional reputation in an academic setting. She specifically opined that Defendant’s statements have damaged Plaintiff’s reputation to a significant degree and that it could take decades, or even a generation, for Plaintiff to restore her reputation, if ever.
Defendant argued that Tallent is not qualified to offer these opinions and that her testimony is unreliable because it is speculative, exaggerated, and unsupported by facts or data tied to Plaintiff’s actual circumstances.
The Court held that Tallent’s education, training, and extensive professional experience in journalism, public relations, and academia qualify her to testify as an expert regarding general principles of reputation, branding, and the ways in which negative publicity — particularly online — can impact professionals in academic environments.
Tallent’s testimony is also relevant. Testimony explaining how reputational harm can occur, how internet-based dissemination differs from traditional media, and how academics may be uniquely vulnerable to reputational injury may assist the trier of fact in understanding issues beyond the knowledge of a lay juror.
However, much of Tallent’s report is framed in conditional or probabilistic terms, such as statements that Defendant’s conduct “ha[s] the capacity” to affect Plaintiff’s reputation or “may cause” harm. Such phrasing underscores the speculative nature of her conclusions and highlights the absence of a reliable basis for opining that reputational harm has in fact occurred, or will occur, to any particular degree. Given the significant weight juries may place on expert testimony, Rule 702 requires more than unsupported statements grounded solely in the expert’s authority. Without a reliable foundation demonstrating how Tallent reached her conclusions about the existence, severity, or duration of Plaintiff’s reputational harm, those opinions risk misleading the jury.
Rebecca Bohn
Bohn began treating Plaintiff in May 2023 and has met with her regularly since that time. Based on her training, clinical experience, and longitudinal treatment of Plaintiff, Bohn diagnosed Plaintiff with post-traumatic stress disorder (“PTSD”) and opined that Plaintiff will require ongoing mental health treatment into the future.
Based on her training, clinical experience, and longitudinal treatment of Plaintiff, Bohn diagnosed Plaintiff with post-traumatic stress disorder (“PTSD”) and opined that Plaintiff will require ongoing mental health treatment into the future.
Defendant argued that Bohn is not qualified to diagnose PTSD, that her opinions are unreliable because they allegedly depart from the DSM-5 diagnostic criteria, and that defamation cannot, as a matter of law or medicine, constitute a qualifying traumatic event.
The Court disagreed and concluded that Bohn is qualified to testify and that Defendant’s challenges go to the weight of her testimony, not its admissibility. Moreover, testimony regarding Plaintiff’s mental health diagnosis, symptoms, treatment history, and prognosis may assist the jury in understanding the nature and scope of the claimed injury and in determining damages, if any. Accordingly, Bohn’s testimony satisfies Rule 702’s relevance requirement.
The Court additionally found Bohn’s testimony sufficiently reliable. As a psychotherapist, licensed mental health counselor, and behavior health educator, she is uniquely qualified to diagnose patients with mental impairments, including PTSD. Defendant’s unsupported argument that defamation cannot constitute a traumatic triggering event sufficient to support a PTSD diagnosis is ultimately a dispute over diagnostic criteria and causation.
Held
The Court granted in part and denied in part the Defendant’s motion to exclude the expert testimony and evidence of Rebecca Bohn and Rebecca Tallent.
Key Takeaway
Unlike an expert retained solely for litigation, Bohn’s opinions are premised upon a course of treatment, repeated clinical evaluations, and an ongoing relationship with Plaintiff. Courts recognize that such medical care provides a reliable basis for diagnostic opinions.
Whether Plaintiff’s experience satisfies the clinical requirements for PTSD are matters on which mental health professions may (or may not) disagree. Such disagreements are appropriately explored through cross-examination and, if Defendant chooses, competing expert testimony. They do not, however, render Bohn’s opinions unreliable for purposes of Rule 702. This is because courts routinely allow expert testimony linking psychological conditions to tortious conduct, including defamation.
Case Details:
| Case Caption: | Scofield V. Guillard |
| Docket Number: | 3:22cv521 |
| Court Name: | United States District Court, Idaho |
| Order Date: | January 23, 2026 |
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