Hakim Ledbetter was charged with: attempted possession with intent to distribute 500 grams or more of methamphetamine, 5 kilograms or more of cocaine, and 1,000 grams or more of PCP and aiding and abetting; possession of a firearm in furtherance of a drug trafficking crime; and possession of a firearm by a felon.
The Government intended to present at trial evidence of Ledbetter’s flight, and “argue that his flight establishes his consciousness of guilt.”
Ledbetter thus sought to introduce Chuck Rylant‘s testimony “regarding psychological and physiological factors that affect human responses to threatening stimuli,” so that the jury could “understand alternative reasons for flight in situations of perceived threat.”
The Government moved in limine to exclude Rylant’s testimony, or in the alternative, for a pretrial Daubert Hearing, arguing that his opinion is irrelevant and inadmissible.
Law Enforcement Expert Witness
Chuck J. Rylant is a former police officer who has investigated and reviewed crimes of violence—including fights, attacks, and homicides—committed with various weapons.
He earned a doctorate in clinical psychology in addition to completing numerous master’s level classes in psychology.
Discussion by the Court
Qualifications
Rylant is not qualified to testify as to Ledbetter’s psychology. Rylant received his “Psy.D.” degree from “California Southern University,” an exclusively online, unaccredited school. While Rylant purports to be an expert on the psychological and physiological limitations of what humans are capable of, the defense presented nothing to establish that Rylant is trained to evaluate the psychological basis for a suspect’s flight from the police. Most of Rylant’s teaching and lecturing occurred when he had earned only an MBA degree—well before he received his “Psy.D.” in 2020.
Rylant’s curriculum vitae confirmed that his specialty is limited to police use of force decisions and self-defense. Moreover, Rylant purportedly could not recall in how many federal criminal cases he was qualified to testify as an expert. Although he initially said that his “understanding” was five cases, he then acknowledged it was three. In those cases, he opined only on the decision to use force. Finally, Rylant acknowledged that he had never before offered an expert opinion on the psychological reasons for a person’s flight from police.
This case does not concern whether police use of force was reasonable, but whether Ledbetter’s flight from police showed consciousness of guilt. In other words, Rylant’s “specialized knowledge” otherwise has nothing to do with Ledbetter or this case. His work on police use of force aside, Rylant has authored two series of books: one titled “How to Be Rich,” and the other, a jiu-jitsu primer.
Reliability
According to the Court, Rylant’s “expert report”—which he drafted in an hour—was exceedingly general, including virtually no mention of the facts of this case. Indeed, Rylant testified that he had essentially cut and pasted his Ledbetter report from strikingly similar reports he had prepared for other cases having nothing to do with flight from the police.
Rylant did not base his “expert” opinion respecting flight from police on reliable methodology. Indeed, Rylant never explained his methodology.
He never spoke with Ledbetter or anyone else about why Ledbetter fled. He never visited the neighborhood where Ledbetter was arrested. Indeed, although he purported to be uncertain, he apparently has never visited Philadelphia. Rylant offered no studies that he or anyone else conducted about flight from police.
Fit – Rule 403
It is apparent that the “fit” of Rylant’s opinion to Ledbetter is poor. He sought to opine that something (which he never clearly identified) other than consciousness of guilt could cause someone in Ledbetter’s circumstances to flee in the manner Ledbetter did. Yet, in forming this opinion, Rylant was ignorant of circumstances that could well have caused Ledbetter to flee from the police. On October 15, 2024, Ledbetter:
- was in violation of his parole because he had left the state of Georgia
- effectively possessed three loaded handguns;
- as a parolee, and a convicted felon, was prohibited from possessing any weapons;
- was driving a truck containing drugs valued at over $1 million;
- had previously fled from police when they executed a warrant;
- had previously been convicted of federal drug charges; and
- had previously shot someone and been convicted of aggravated assault.
Rylant then reluctantly acknowledged that this new information could have provided reasons for why someone in Ledbetter’s circumstances would run from police. The potential for prejudice and jury confusion arising from the Government’s “other reasons for flight evidence”—with its attendant cautionary instructions—would plainly outweigh the probative value of Rylant’s unreliable opinion, which he was not qualified to give.
Rule 704
Rule 704(b) still prohibits an expert from opining about the “possible” mental state of a Defendant. Accordingly, the Court determined that the defense’s attempt to end-run Rule 704(b) was impermissible.
Held
The Court ruled that because Chuck Rylant’s proffered opinion did not pass muster under Rules 702, 704, and 403, he could not testify at trial.
Key Takeaway
Although proffered to opine on Hakim Ledbetter’s psychology, Rylant is not and has never been a psychologist. His “Psy.D.” was conferred in 2020 by an unaccredited, exclusively online institution. He appears never to have testified, written, or lectured on the issue he was called to address: the psychology of a suspect fleeing from police. The three federal cases in which he purportedly testified bear no resemblance to Ledbetter. Rylant’s methodology is unknown.
Although he purported to base his opinion only on generalities, he “revised” that basis and impermissibly strayed into his belief that Defendant lacked mens rea in fleeing from police. Admitting Rylant’s opinion would thus likely open the door to other explanations highly damaging to Ledbetter—about why he fled, as well as cautionary instructions, which would certainly confuse the jury.
Case Details:
| Case Caption: | United States V. Ledbetter |
| Docket Number: | 2:24cr423 |
| Court Name: | United States District Court, Pennsylvania Eastern |
| Order Date: | April 02, 2026 |
