This suit arises from the death of Plaintiffs Mónica E. Gonzalez-Lopez’s and José L. Rodríguez-Sánchez’s (collectively, “Plaintiffs”) son, Christian José Rodríguez-González (Rodríguez), who was shot and killed during a police chase carried out by Defendants Officer Alberto Robles-Concepción (“Robles”) and Officer Emanual Ramos-Pabón (“Ramos”) on July 15, 2022.
Plaintiffs Monica E. Gonzalez-Lopez and Jose L. Rodriguez-Sanchez (collectively, “Plaintiffs”) filed a motion in limine to preclude the testimony of Janeliz Rodriguez, an expert for Defendants Municipality of San Juan, Mayor Miguel A. Romero-Lugo, Commissioner Juan J. Garcia, Alberto Robles-Concepcion, and Emmanuel Ramos-Pabon.
Forensic Expert Witness
Janeliz Rodriguez Disla possesses a Bachelor’s in Criminal Justice; a private detective certification from a forensic college at which she now teaches; numerous certificates in evidence analysis, evidence handling, forensics, and forensic photography; over fourteen years of work experience, including in analyzing security camera videos; several licenses as a private investigator; and experience in at least three federal court cases involving the forensic analysis of videos and photos.
Discussion by the Court
In the challenged statement, Rodriguez described a “long and dark object” as “consistent with being a long weapon or rifle.” Defendants responded that the objective of Rodriguez’s expert report is analyzing the entire video, that her statement is a narrow and qualified description of what was visible in the image, and that Rodriguez is qualified to identify an object as consistent with a long weapon.
In the case at bar, the Court found that Rodriguez’s description of a “long and dark object” as “consistent with being a long weapon or rifle,” is admissible because Rodriguez is qualified to so characterize the object on account of her qualifications in forensic video analysis and criminal justice and her work experience as a detective and investigator. Moreover, even assuming Rodriguez was not an expert, her testimony regarding the object is unremarkable and perception-based observation, which the case law permits even lay witnesses to offer.
The Court found that Defendants have shown that Rodriguez possesses the qualifications and work experience necessary to analyze the video in question and to make the comparison challenged by Plaintiffs.
Held
The Court denied Plaintiffs’ motion in limine to preclude the testimony of Janeliz Rodriguez.
Key Takeaway
The characterization of a “long and dark object” as “consistent with being a long weapon or rifle” is admissible as a run-of-the-mill observation about the object’s purported visible shape and silhouette. The statement challenged by Plaintiffs does not identify technical specifications such as make, model, operability, or any other such ballistics-based assertions. This sort of ordinary description is rationally based on perception, in line with the strictures of even Fed. R. Evid. 701. Moreover, the fact that the statement includes the qualified phrase “consistent with”–in place of a more definite assertion that the “long and dark object” is certainly a weapon–further militates in favor of admitting it.
Case Details:
| Case Caption: | Gonzalez-Lopez V. Municipality Of San Juan |
| Docket Number: | 3:23cv1278 |
| Court Name: | United States District Court, Puerto Rico |
| Order Date: | January 28, 2026 |
Leave a Reply