Expert Witness Profiler

Tag: Diagnose

  • Psychology Expert’s CPTSD Opinions Admitted

    Psychology Expert’s CPTSD Opinions Admitted

    Danesh Noshirvan, an online entertainer and journalist, filed a civil action against Jennifer Couture alleging conspiracy and agency liability, as well as claims for defamation, tortious interference, misappropriation of likeness, and intentional infliction of emotional distress.

    Noshirvan alleged that Couture, Dr. Ralph Garramone, M.D. and OMG Realty, LLC , along with the other named Co-Defendants, conspired with a non-party, Joseph Camp (“Camp”) to tortiously interfere with Plaintiff’s business relationship with his former attorney, defame Plaintiff and intentionally inflict emotional distress upon Plaintiff.

    Garramone Plastic Surgery, Jennifer Couture, Ralph Garramone, and OMG Realty, LLC challenged the testimony of Robert M. Gordon, Ph.D., ABPP.

    Gordon diagnosed Noshirvan with Complex Post-Traumatic Stress Disorder “due to the cyberbullying and damage to his reputation by Joey Camp.” He further opined that Noshirvan would “need many years of intensive psychotherapy to help deal with his CPTSD.”

    Psychology Expert Witness 

    Robert M. Gordon, Ph.D., ABPP has practiced forensic psychology for nearly five decades (since 1976) in both civil and criminal arenas. He is board-certified in Clinical Psychology and in Psychoanalysis, and earned his
    doctorate from Temple University.

    He has authored over 100 publications in areas directly relevant to this case. For example, he co-published research on using the MMPI-2 to detect individuals “faking PTSD” after traumatic events.

    Gordon has taught forensic psychology at the Ph.D. level and given international workshops on psychological assessment and trauma.

    Discover more cases with Robert Gordon as an expert witness by ordering his comprehensive Expert Witness Profile report.

    Discussion by the Court

    A. Reliability of Methodology

    (1) Post-Traumatic Stress Disorder

    Defendants argued that Gordon’s use of the Clinician Administered PTSD Assessment Questionnaire for DSM-5 (“CAPS-5”) is unreliable.

    Specifically, Defendants pointed out that the DSM-5 requires “exposure to actual or threatened death, serious injury, or sexual violence” and the “presence of one or more of certain symptoms associated with the traumatic events, beginning after the traumatic events occurred.”

    Yet Gordon, according to Defendants, bases his diagnosis on the assertion of “cyberbullying and destruction of reputation.” Since Gordon, according to Defendants, failed to strictly adhere to the diagnostic criteria in the DSM-5, the Defendants contended that Gordon’s testimony must be unreliable.

    First, Defendants argued that Gordon lacked any evidence of exposure to actual or threatened death, serious injury, or sexual violence, because he conducted no independent investigation on Noshirvan’s allegations in the Second Amended Complaint and interview. Any quarrel with not independently verifying any of the allegations that Noshirvan presented to Gordon can be appropriately dealt with on cross-examination.

    Defendants next argued that Gordon failed to follow DSM-5 diagnostic criteria because he did not observe at least one month’s worth of PTSD symptoms before diagnosing a patient with PTSD and relied almost exclusively on Plaintiff’s self-reporting. While Defendants contended that the rationale for using these specific tests was not definitively explained, such concern can be considered through cross-examination and is not a reason to exclude Gordon’s testimony.

    Further, Defendants also pointed the Court to the Georgetown Guidelines for Forensic Assessment of PTSD. However, it too is not enough to show the methodology is unreliable since those guidelines were published before the DSM-5 and did not outline any specific examinations that must be given. Accordingly, the Defendants have not shown that Gordon’s methodology was unreliable as it relates to his diagnosis of PTSD.

    (2) Complex Post-Traumatic Stress Disorder

    Defendants also argued that Gordon’s failure to adhere to the diagnostic criteria of Complex Post-Traumatic Stress Disorder (“CPTSD”) in the ICD-11 as well as his diagnosis being made solely for the purpose of litigation rendered his methodology unreliable.

    Gordon relied on more than mere allegations presented by Plaintiff. Gordon utilized an array of psychological assessments to determine the presence and severity of the symptoms before making any diagnosis. To the extent Defendants disagreed with the diagnosis, they were free to challenge Gordon on cross-examination.

    Defendants next argued that Gordon failed to explain the results of the International Trauma Questionnaire (ITQ) or how he reached the diagnosis of CPTSD.

    However, Defendants failed to show how that the ITQ itself is unreliable, and though how Gordon exactly utilized the ITQ is unknown, it is clear that he still relied upon the underlying PTSD diagnosis in reaching his conclusion.

    Finally, Defendants argued that Gordon’s CPTSD diagnosis was made solely for purposes of this litigation. Defendants contended that while it is not dispositive, it further weighs against the reliability of Gordon’s testimony since Noshirvan only met with Gordon for about an hour via Zoom and was not re-examined in the future. While it is true Gordon only met with Noshirvan for about an hour, this argument went to the credibility of Gordon, not the reliability of his methodology.

    B. Helpfulness

    It is undisputed that Gordon utilized the CAPS-5, ITQ, Brief Psychiatric Rating Scale, Beck Depression Inventory-II, Beck Anxiety Inventory, and Miller Forensic Assessment of Symptoms Test. Although Defendants took issue with the conclusions reached by Gordon as well as the methods utilized, the conclusions went to a crucial issue in this case—whether Noshirvan suffered emotional distress.

    Further, Defendants acknowledged that the diagnostic criteria of PTSD and CPTSD is beyond the understanding of the average lay person. Defendants were able to cross-examine Gordon regarding why he utilized the specific tests in lieu of other examinations they contended are better suited for such diagnosis. These quarrels, however, are not sufficient to exclude the evidence.

    Ultimately, the Court found that Gordon satisfied all three prongs of Daubert, and the Court found that no undue prejudice from the anticipated testimony.

    Held

    • The Court denied as moot Defendant Garramone Plastic Surgery’s motion to exclude the testimony of Robert M. Gordon, Ph.D., ABPP.
    • Jennifer Couture, Ralph Garramone, and OMG Realty, LLC’s motion to exclude the testimony of Robert M. Gordon, Ph.D., ABPP was denied.
    • Garramone Plastic Surgery’s motion to exclude the testimony of Robert M. Gordon, Ph.D., ABPP was denied.
    • Patrick Trainor, Central Park of Southwest Florida, LLC, and Anti-Doxing League, Inc.’s motion to exclude the testimony of Robert M. Gordon, Ph.D., ABPP was denied.

    Key Takeaway

    Gordon satisfied all three prongs of Daubert because he utilized an array of psychological assessments to determine the presence and severity of the symptoms before making any diagnosis.

    Further, Defendants acknowledged that the diagnostic criteria of PTSD and CPTSD is beyond the understanding of the average lay person.

    Case Details:

    Case Caption: Noshirvan V. Couture
    Docket Number: 2:23cv1218
    Court Name: United States District Court, Florida Middle
    Order Date: March 13, 2026

  • Psychology Expert Allowed to Opine on EMDR Therapy

    Psychology Expert Allowed to Opine on EMDR Therapy

    Oriental Trading Company, Inc. (“OTC”) is a retailer of novelties and gifts. Plaintiff Keith Kirksey is an African American male who began his employment with OTC on or about June 1, 2017.

    According to Kirksey, during his employment, he experienced a series of racially targeted incidents including the placing of a noose in his workspace and the placing of a clown head with, what he perceived as, a noose around its neck where Kirksey would see it. He reported these incidents to OTC who indicated it would investigate. Kirksey was dissatisfied with OTC’s investigation, and its outcome, and thereafter felt unfairly targeted by OTC in retaliation for his reporting.

    Kirksey filed a complaint against OTC stemming from his employment alleging claims of race discrimination, retaliation, and harassment/hostile work environment as well as negligent infliction of emotional distress.

    In an effort to establish his claims, Kirksey engaged Jerry Authier, Ph.D. as an expert. Authier is clinical psychologist licensed in Nebraska who was retained to conduct a psychological evaluation of Kirksey. In an effort to rebuke Kirksey’s claims, OTC designated Timothy D. Loudon as an expert in the field of human resources and workplace investigations.

    OTC filed a motion in limine to exclude the testimony of Plaintiff’s expert witness Authier and Kirksey filed a motion to exclude the testimony of Loudon.

    Psychology Expert Witness

    Jerry L. Authier, Ph.D. is a clinical psychologist licensed in Nebraska. He has been practicing psychology in Omaha since 1973.

    He obtained his bachelor’s degree in psychology and doctorate in clinical psychology. Throughout his 50-year career, Authier was the director of behavioral science at the University of Nebraska and Clarkson Family Medicine and saw patients in private practice. Authier has authored various articles and books and presented at a range of conferences, primarily during his years as an educator.

    Discover more cases with Jerry Authier as an expert witness by ordering his comprehensive Expert Witness Profile report.

    Human Resources Expert Witness

    Timothy D. Loudon has a juris doctor degree, is licensed to practice law in multiple states, and has practiced labor and employment law in various capacities since 1981.

    Want to know more about the challenges Timothy Loudon has faced? Get the full details with our Challenge Study report.

    Discussion by the Court

    Authier

    OTC did not move to preclude Authier from testifying altogether but sought
    to limit his testimony to that of a treating provider. OTC primarily argued that Authier’s opinions should be excluded because the foundation of Authier’s opinions rest solely on information Kirksey (and perhaps his counsel) conveyed to him.

    Authier opined that Kirksey suffers from post-traumatic stress disorder, persistent depressive disorder with paranoid ideation, and generalized anxiety disorder. He further concluded that Kirksey’s negative psychological and psychiatric symptoms are attributable to Kirksey’s time working at OTC. In reaching these conclusions, Authier used a diagnostic interview, Minnesota Multiphasic Personality Inventory, 2nd Edition (“MMPI-2”) and the Sachs Sentence Completion Test. Authier further opined that Kirksey would need weekly psychotherapy sessions for an indeterminate amount of time but “at least a year if not longer and possibly the rest of his life.”

    During his deposition, taken almost a year after his diagnostic interview, Authier testified that Kirksey did not participate in weekly therapy sessions with him. Authier stated that at the time he wrote his opinion he believed weekly therapy sessions would be the best way for Kirksey to recover from his symptoms.

    Authier further testified that he is not an expert in EMDR therapy but stated it might be of help to Kirksey, when done with a specialized provider, to work through some of the symptoms of trauma. Similarly, Authier testified that he is not licensed to prescribe medication but that “the research shows that [psychotherapy along with medication] is the best way to help people that are struggling with psychiatric and psychological symptoms.

    Analysis

    First, OTC argued that Authier’s opinions are irrelevant because the June 18, 2020, incident (of which Authier’s opinion relies) is outside the applicable statute of limitations for Plaintiff’s claims in this lawsuit.

    However, the Court found that Authier’s opinions regarding Kirksey’s conditions and the source of those conditions is wholly relevant to the ultimate issues in this case and his testimony would be useful to the finder in fact when deciding those issues.

    OTC sought to exclude Authier’s opinions as to EMDR therapy and psychotropic medications based on his qualifications. While Authier testified that he is not an expert in EMDR nor a medical doctor, his limited opinions on these two topics fall within his purview of a clinical psychologist.

    Authier did consider whether Kirksey’s symptoms could be attributable to other causes – such as childhood trauma. He determined based on his testing and clinical experience that this was unlikely. Moreover, when presented with records from a prior provider, Authier did not change his opinion.

    The Defendant did not identify any plausible alternative cause of Kirksey’s conditions, thus strengthening the Court’s conclusion that the methodology employed by Authier is reliable. In addition to the diagnostic interview, Authier had approximately 16 sessions with Kirksey which confirmed Authier’s impressions and diagnosis of Kirksey.

    Authier’s clinical impressions, based on his standardized diagnostic tools and his diagnostic evaluation, is that Kirksey is experiencing symptoms and those symptoms are tied to his time at OTC.

    Moreover, OTC sought to exclude Authier’s opinion relating to his original recommendation that Kirksey participate in weekly psychotherapy sessions, arguing it is speculative and unsupported by the facts. The Court found that this information may provide context to the testimony at trial.

    Loudon

    Loudon opined about OTC’s handling of each of Kirksey’s complaints. To sustain a claim against OTC for a racially hostile work environment, Kirksey must show (1) he is a member of a protected group, (2) he was subjected to unwelcome harassment, (3) the harassment was based upon race, (4) the harassment affected a term, condition, or privilege of employment, and (5) the employer knew or should have known of the racially discriminatory harassment and failed to take prompt and effective remedial measures to end the harassment.

    At the time of trial, the “promptness” and “effectiveness” of an employer’s response is a question of fact for the jury to resolve and a matter for the Court to instruct.

    Allowing Loudon to testify as an expert to the “adequacy” and “reasonableness” of OTC’s investigation would invade the province of the jury.

    Held

    • The Court denied Defendant Oriental Trading Company’s motion in limine to exclude the testimony of Plaintiff’s expert witness Jerry Authier.
    • The Court granted Plaintiff Keith Kirksey’s motion to exclude the testimony of Timothy Loudon.

    Key Takeaway

    With respect to differential diagnosis, opinion testimony is unreliable “only when an opponent points to a plausible alternative cause of the injury and the doctor offers no explanation for concluding that it was not the sole cause.”

    OTC’s attacks regarding the completeness of Authier’s methodology go to the weight and not the admissibility of his testimony.

    Case Details:

    Case Caption: Kirksey V. Oriental Trading Company Inc.
    Docket Number: 8:24cv268
    Court Name: United States District Court, Nebraska
    Order Date: March 09, 2026
  • Psychology Expert’s Opinion on Social-Media-Facilitated Sex Trafficking Admitted

    Psychology Expert’s Opinion on Social-Media-Facilitated Sex Trafficking Admitted

    This case arises under the Trafficking Victims Protection Reauthorization Act (TVPRA), which provides victims of sex trafficking a civil remedy against the perpetrators and beneficiaries of their trafficking.

    Plaintiff Doe (C.L.F.) filed this action to recover for alleged harm she experienced from being trafficked at a Motel 6 in Wichita, Kansas, that she claims was owned and operated by the Defendants.

    Defendant Kisan, Inc. filed a motion to exclude the testimony of Dr. Katy Fowler Sutton, one of C.L.F.’s designated expert witnesses. 

    Psychology Expert Witness

    Kathryn Fowler Sutton graduated with a Master of Science in Clinical Psychology and in 2004 received her Doctor of Clinical Psychology (PsyD). She has been a Licensed Specialist in School Psychology (Texas) since 2005 and a Licensed Clinical Psychologist (Texas) since 2006. In her twenty years of clinical practice, approximately 15% of her patients have been survivors of sex trafficking. As part of her annual license renewal requirements, she has to complete mandatory training in human trafficking.

    She also has fourteen years of experience being an expert witness and has never before been struck. In addition to being an expert witness, she also currently continues to see patients, some of whom are sex trafficking survivors.

    Want to know more about the challenges Katy Fowler Sutton has faced? Get the full details with our Challenge Study report. 

    Discussion by the Court

    Kisan and the G6 Defendants sought to exclude Sutton’s opinions that

    (1) C.L.F. meets the criteria of Post-Traumatic Stress Disorder (PTSD) and other specified trauma-and-stressor-related disorders; and

    (2) C.L.F.’s PTSD is caused by her having been sex-trafficked rather than any other previous traumatic experiences.

    Defendants claimed that these opinions should be excluded because they are both irrelevant and unreliable.

    A. Relevance

    Defendants argued that the testimony of Sutton is inadmissible because it is irrelevant.

    According to Defendants, the fatal flaw in Sutton’s report is that “the word ‘motel’ does not appear.” Worse yet, the report stated that C.L.F.’s alleged trafficking was “facilitated by social media platforms.” In this case, the alleged trafficking occurred only at motels owned and operated by Defendants, and C.L.F. “met her trafficker at a gas station,” not on social media. This might be problematic as expert testimony must be connected to “the facts of the case.” 

    While a report based on social-media-facilitated sex trafficking at no specific locations may not be tied to the facts of this case, Sutton’s report is. Sutton interviewed C.L.F. for 5 hours and 12 minutes. During that time, Sutton and C.L.F. discussed C.L.F.’s early life in detail, C.L.F.’s experiences during the alleged trafficking, and C.L.F.’s recovery in recent years. They specifically talked about her “thoughts and feelings” associated with the alleged trafficking, and Sutton collected enough information to provide diagnoses of and recommended treatments to C.L.F.

    Further, in her deposition Sutton explicitly confirmed that she tied her interview with C.L.F. to the facts of this case. Sutton used the complaint during the interview to “refer specifically to the incident[s] in question” at the motels in issue. When asked if they discussed the relevant motels “where [C.L.F.] had a traumatic experience,” Sutton responded: “Yes.” During the interview, Sutton ensured to “very specifically explain to C.L.F. what events [she was] referring to.” In the Court’s view, Sutton’s methodology was “sufficiently tied to the facts of the case.”

    The Court held that her testimony was relevant under Rule 702.

    B. Reliability

    Defendants asserted that the two opinions they want stricken should be excluded because they are unreliable. To Defendants, Sutton’s opinions are not the product of a reliable methodology and do not reflect a reliable application of psychology to the facts of the case.

    1. Sutton’s Diagnosis of C.L.F.’s PTSD and Other Trauma Disorders

    Defendants objected to Sutton’s opinion that C.L.F. met the criteria for PTSD and other specified trauma-and-stressor-related disorders.

    First, Defendants argued that Sutton’s diagnosis is unreliable because she “did not follow accepted medical practice in selecting or administering tests” for PTSD in her interview of C.L.F.

    The Court understood Defendants’ stance, but ultimately their attacks are best left for “[v]igorous cross-examination.” To admit Sutton’s testimony, C.L.F. “need not prove to th[is court] that the expert’s testimony is correct;” she simply must “prove by a preponderance of the evidence that the testimony is reliable.” Even with its alleged flaws, Sutton’s opinion that C.L.F. met the criteria for PTSD is reliable by a preponderance of the evidence.

    Defendants also found fault with Sutton’s administration of the CAPS-5, specifically her failure to use the Life Events Checklist (LEC-5) during CAPS-5 Step 1. They said that because Sutton did not use the LEC-5 for the Step 1 inquiry, her opinions are unreliable to the point of inadmissibility. But CAPS-5 allows the practitioner to administer the LEC-5 or some “other structured trauma screen” to begin. Sutton’s report, as noted, details information about C.L.F.’s history of trauma gleaned from the hours-long interview Sutton conducted of C.L.F., which in the Court’s view qualifies as a structured trauma screen.

    Second, Defendants argued that Sutton’s diagnosis of C.L.F. with PTSD is unreliable because Sutton’s conclusion contains conflicting diagnoses. However, the Court did not accept that Sutton’s “conflicting diagnoses” are so unreliable that they defy the “methods and procedures of science.” 

    2. Sutton’s opinion that sex-trafficking, not other traumatic experiences, caused C.L.F.’s PTSD

    Defendants took issue with Sutton’s opinion that C.L.F.’s “history of trafficking,” not any of her other previous traumatic experiences, caused her PTSD.

    As Sutton noted in her report (and as Defendants state in their motion), the stressors with potential to cause PTSD for C.L.F. other than her trafficking experiences are the death of her grandmother, her placement in foster care, the incarceration of her first child’s father, her abusive relationship circa 2020, and apparent substance abuse. Defendants claimed that Sutton only ruled out C.L.F.’s grandmother’s death and her placement in foster care before declaring that C.L.F.’s trafficking experiences were the sole cause of her PTSD. Sutton certainly did rule those stressors out; she concluded “within a reasonable degree of scientific certainty” that C.L.F.’s PTSD responses are associated with her history of trafficking, not the “grief” she experienced from her grandmother’s death or foster care.

    Now Sutton did not explicitly rule out all potential causes, but her report evidences that she was aware of these other stressors when opining on the cause of C.L.F.’s PTSD. While the Court felt that Sutton should improve her recordkeeping and notetaking as it pertains to conducting diagnoses for litigation, her extensive experience with evaluations, her five-hour interaction with C.L.F., her deposition testimony, and the conclusions in her report all favor reliability here.

    C. Scope

    Though Sutton can testify as to her opinion that C.L.F.’s PTSD was caused by the trafficking-related trauma discussed during the evaluation, the Defendants pointed out that Sutton may not characterize any incidents C.L.F. experienced as “sex trafficking.” Sutton’s report and testimony is rife with her calling the incidents C.L.F. discussed “sex-trafficking.” The Court agreed. Defendants are right to point out that Sutton is not permitted to opine on ultimate legal issues. 

    In other words, Sutton may provide her opinion that C.L.F. suffers from PTSD and other trauma disorders, and she may provide her opinion as to what caused C.L.F.’s PTSD. But in describing these causes, she must keep her descriptions within certain limitations.

    Held

    The Court denied in part the Defendant Kisan, Inc.’s motion to exclude the proposed testimony of Plaintiff’s expert Dr. Kathryn Sutton.

    Key Takeaway:

    Sutton is free to discuss the trauma-causing incidents concerning C.L.F., but only in permissible ways. The Court is aware that these incidents necessarily involve sex or even commercial sex, but the testimony is permissible so long as it does not characterize any experiences or incidents as sex trafficking or trafficking.

    Case Details:

    Case Caption: Doe C.L.F. V. G6 Hospitality, LLC
    Docket Number: 1:23cv303
    Court Name: United States District Court, Texas Eastern
    Order Date: August 20, 2025
  • Criminology Expert’s Opinions about Post-Incarceration Syndrome are Unreliable

    Criminology Expert’s Opinions about Post-Incarceration Syndrome are Unreliable

    Kuantay Reeder was convicted by a jury of second-degree murder in 1995. He spent approximately 26 years in prison before his conviction was vacated and he was released.

    Reeder now sues the Orleans Parish District Attorney’s Office (“OPDA”), alleging that suppression of favorable evidence during his criminal proceedings caused him to be wrongfully convicted and imprisoned.

    Reeder has retained Christian Bolden, Ph.D. to provide expert testimony in support of his claim for damages. Defendant, Jason R. Williams, in his official capacity as Orleans Parish District Attorney, filed a motion to exclude the testimony of Bolden.

    Criminology Expert Witness

    Christian L. Bolden, Ph.D. is an associate professor and department chair of Criminology and Justice at Loyola University New Orleans. He is a sociologist and criminologist specializing in street gangs, human trafficking, and the life histories and reentry trajectory of individuals who were incarcerated more than 20 years.

    As part of his work, Bolden has interviewed numerous individuals who were formerly serving life or de facto life sentences in Louisiana. Bolden teaches undergraduate and graduate courses on the causes, consequences, and experiences of incarceration.

    Want to know more about the challenges Christian Bolden has faced? Get the full details with our Challenge Study report. 

    Discussion by the Court

    Bolden interviewed Reeder by telephone to discuss Reeder’s experiences in prison and the problems that Reeder has faced following his release. Bolden has produced an expert report in which he has opined that Reeder is experiencing symptoms consistent with the criteria for post-incarceration syndrome. 

    The possible existence of a particular species  of PTSD called post-incarceration syndrome (PIS) that may be experienced by ex-prisoners who are released from serving a life sentence was discussed in an article published in 2013 by two researchers. For the article, the researchers conducted exploratory research by interviewing 25 ex-prisoners, and based on the results the researchers argued that additional research into PIS should be conducted. They also argued in favor of modifying the PTSD diagnosis found in the Diagnostic and Statistical Manual of Mental Disorders, fifth edition (DSM-V), to include criteria for PIS as a subtype of PTSD. For whatever reasons, this did not occur.

    To begin with, Bolden testified that he has never testified as an expert on PIS and was not aware of any other expert who had testified in court as an expert in PIS. Bolden described his area of expertise as “the experiences of incarceration,” and that PIS is “just one minor thing that fits into that.”

    Moreover, Bolden denied that he was diagnosing Reeder with PIS because sociologists do not diagnose individuals, and they do not study individual behavior, Bolden admitted that he was not qualified to diagnose individual persons with mental health disorders. Basically, Bolden clarified that he was not diagnosing him with PIS but rather is opining that Reeder’s symptoms match the characteristics of PIS; that he fits the pattern.

    Motion to Exclude

    Williams argued that PIS has not been generally accepted or proven in the scientific community, that Bolden’s expertise does not allow him to opine as to whether Reeder suffers from it (assuming that PIS is even a legitimate mental health syndrome), and therefore that Bolden’s opinions are irrelevant.

    Williams added that Bolden’s testimony, which relied completely on the diagnosis provided by Reeder’s expert psychologist, is cumulative of her testimony.

    The Court found that Bolden’s testimony should be excluded for nearly all the reasons raised by Williams. PIS was presented as a mental health disorder, but Bolden himself admitted he was not qualified to diagnose Reeder with PIS or any other psychological condition. His expertise pertains to groups and group characteristics, not individual diagnoses. At most, Bolden could state that Reeder—who had already been diagnosed with multiple mental health disorders by a qualified psychologist—showed symptoms similar to those seen in some other former prisoners. However, that opinion is not probative of Reeder’s claim for damages.

    Moreover, since Reeder intended to testify personally about his traumatic prison experiences, Bolden could not speak on his behalf.

    Held

    The Court granted the Defendant’s motion to exclude the testimony of Christian Bolden. 

    Key Takeaway:

    The Court may exclude relevant evidence if its probative value is substantially outweighed by a danger of one or more of the following: unfair prejudice, confusing the issues, misleading the jury, undue delay, wasting time, or needlessly presenting cumulative evidence. 

    Case Details:

    Case Caption: Reeder V. Williams Et Al
    Docket Number: 2:22cv4614
    Court Name: United States District Court for the Eastern District of Louisiana
    Order Date: June 17, 2025