Tag: Disorder

  • Psychiatry Expert Allowed to Opine on Psychological Injuries

    Psychiatry Expert Allowed to Opine on Psychological Injuries

    Plaintiff Brigid “Bridie” Farrell alleged that Defendant Gabel groomed and sexually abused her from June 1997 to January 1998.

    Plaintiff filed a motion to exclude the expert testimony of Defendants’ expert, Dr. Charles Saldanha, pursuant to Rule 702 of the Federal Rules of Evidence.

    Psychiatry Expert Witness

    Charles Edwin Saldanha graduated from Emory University with a Bachelor of Arts in Economics and completed his Doctor of Medicine degree at the Duke University School of Medicine. After internship at the Brigham and Women’s Hospital, he completed residency in Psychiatry at the University of California, San Francisco (UCSF) and a fellowship in Forensic Psychiatry at Yale University. He is certified in Psychiatry with Added Qualifications in Forensic Psychiatry by the American Board of Psychiatry and Neurology.

    Saldanha has practiced in the areas of emergency psychiatry, inpatient psychiatry, and community psychiatry with a focus on persons with serious mental illness.

    Saldanha has performed over 60 forensic psychiatric evaluations and has testified over 25 times in court proceedings and depositions.

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

    Discussion by the Court

    1. Qualifications

    Plaintiff is an adult who alleged that she suffered from psychiatric conditions due to sexual abuse she suffered as a teenager. She argued that Saldanha is not qualified as an expert “due to his lack of experience in child psychiatry.”

    Saldanha, however, has “superior knowledge, education, experience, or skill” in general and forensic psychiatry. Saldanha describes his work experience to “include clinical work with diverse behavioral health populations spanning a range of ages, primary diagnoses, comorbidities, and psychosocial backgrounds, including persons who have suffered sexual assault and abuse.”

    Accordingly, the Court concluded that, based on Saldanha’s education, experience and skill, he qualifies as an expert to give his opinion on Plaintiff’s emotional injuries as a result of the sexual and mental abuse.

    2. Reliability

    Saldanha opined that, “though Plaintiff’s records indicate that some treaters have also diagnosed PTSD or listed it as a rule out diagnosis, the information available does not support this diagnosis.” To arrive at this conclusion, Saldanha reasoned that, “since the abuse, Plaintiff has not shown a consistent presence of avoidance of stimuli associated with the abuse or marked alterations in arousal and reactivity, domains of symptoms which are present in PTSD.” Saldanha noted that, “since this episode of abuse, Plaintiff has not shown persistent avoidance of or efforts to avoid memories, thoughts, or feelings related to the events or people, places, activities, or situations related to the abuse.” Saldanha further asserted that, although “psychological testing performed as part of the evaluation showed significant emotional distress, it did not support the diagnosis of PTSD.”

    The Court concluded that, by outlining the symptoms that he looks for when identifying cases of PTSD and explaining why, in his opinion, Plaintiff is not experiencing these symptoms, Saldanha adequately explained the methodology he used to reach his conclusion.

    Saldanha explained that, in his opinion, the symptoms Plaintiff described were more consistent with major depressive disorder than with PTSD. Saldanha clearly articulated that, because Plaintiff was not exhibiting avoidance of stimuli or changes in reactivity, he did not believe that a PTSD diagnosis was appropriate.

    Furthermore, the Court concluded that Plaintiff’s contention that Saldanha is merely acting as an “advocate for a cause” and that, therefore, the Court should exclude his testimony as unreliable, is unavailing. To the contrary, in his report, Saldanha acknowledged that Plaintiff is experiencing psychological issues such as major depressive disorder.

    3. Relevance

    In this case, whether Plaintiff suffered psychological injury as a result of Defendant Gabel’s alleged abuse is a critical issue in this case. Saldanha’s expert opinion is directly relevant to both the psychological issues from which Plaintiff suffers and the cause of those problems.

    Accordingly, the Court found that Saldanha’s expert testimony is relevant to the issues in this case.

    Held

    The Court denied Plaintiff’s motion to exclude the testimony of Dr. Charles Saldanha.

    Key Takeaway

    The Court noted that, in assessing reliability, the principles and methodology employed should be assessed, not the outcome of those methods. Moreover, it is not unusual for reasonable minds to differ even when both apply reliable methodology in reaching such differing conclusions. For all these reasons, the Court concluded that Plaintiff’s displeasure with Saldanha’s conclusion is not a ground for excluding him from testifying.

    Case Details:

    Case Caption: Farrell V. The United States Olympic & Paralympic Committee
    Docket Number: 1:20cv1178
    Court Name: United States District Court for the Northern District of New York
    Order Date: June 17, 2026
  • 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