Huff v. City of Aurora, Colorado, The

CourtDistrict Court, D. Colorado
DecidedMarch 15, 2024
Docket1:21-cv-02715
StatusUnknown

This text of Huff v. City of Aurora, Colorado, The (Huff v. City of Aurora, Colorado, The) is published on Counsel Stack Legal Research, covering District Court, D. Colorado primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Huff v. City of Aurora, Colorado, The, (D. Colo. 2024).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Judge Regina M. Rodriguez

Civil Action No. 1:21-cv-02715-RMR-NRN

ANDREW GLENN HUFF, an individual,

Plaintiffs,

v.

THE CITY OF AURORA, COLORADO, and OFFICER ALEXANDER ORD, in his individual capacity,

Defendants.

ORDER

This matter is before the Court on Defendant Alexander Ord’s (“Officer Ord”)1 Motion to Exclude Expert Testimony of Natasha Powers, ECF No. 72. The Motion is fully briefed and ripe for review. For the following reasons, Officer Ord’s Motion is GRANTED IN PART and DENIED IN PART. I. BACKGROUND On the evening of October 19, 2019, at 11:30 p.m., Aurora Police Officer Alexander Ord shot Andrew Huff (“Plaintiff”) while Plaintiff stood in the window of his home with a rifle in his hand. Officer Ord, along with two other officers, state that they arrived at the residence to investigate a charge that Plaintiff and his brother had assaulted a third party

1 Defendant The City of Aurora, Colorado did not join Officer Ord’s motion or state a position as to the motion to exclude. earlier in the day. The exact events of the evening are in dispute. There appears to be significant dispute over key facts such as: whether Plaintiff was aware the officers were police officers, whether the police officers announced themselves as police, and whether Plaintiff pointed the gun he held toward the officers. What is not disputed is that when Officer Ord saw the gun Plaintiff was holding, he fired five shots at Huff. One of the shots hit Plaintiff, passed through his rectum, and became lodged in his pelvis. Plaintiff alleges the shooting was unwarranted and therefore asserts an excessive force claim under the Fourth Amendment against Officer Ord and the City of Aurora. In support of his claims, Plaintiff endorsed Natasha Powers (“Powers”), a former

police officer, as a use-of-force expert witness to address standards of police conduct raised by the circumstances under which Officer Ord shot Plaintiff. Powers’s report indicates that she will opine on three topics: 1. Did Ofc. Alexander Ord exercise good judgment? 2. Were Ofc. Alexander Ord’s actions in concert with established police practices and guidelines? 3. Would reasonably trained and prudent police officers likely have performed in the same manner as Ofc. Alexander Ord did, given the same or similar circumstances as presented in this case? ECF No. 72-1 at 3, Powers Report, dated January 23, 2023. II. Legal Standard Federal Rule of Evidence 702 requires that expert testimony is not only relevant, but reliable.’” United States v. Gabaldon, 389 F.3d 1090, 1098 (10th Cir. 2004) (quoting Daubert v. Merrell Dow Pharm., Inc., 509 U.S. 579, 589 (1993). The Court is the gatekeeper and the party offering such testimony bears the burden of demonstrating the evidence is reliable and relevant. U.S. Aviation Underwriters, Inc. v. Pilatus Bus. Aircraft, Ltd., 582 F.3d 1131, 1149 (10th Cir. 2009). The gatekeeper function requires the court perform “a two-step analysis.” Roe v. FCA US LLC, 42 F.4th 1175, 1180 (10th Cir. 2022); see also 103 Investors I, L.P. v. Square D Co., 470 F.3d 985, 990 (10th Cir. 2006). First, the court must determine whether the expert is qualified by “knowledge, skill, experience, training, or education” to render an opinion. Roe, 42 F.4th at 1180 (quoting Fed. R. Evid. 702). The parties do not dispute Powers’s qualifications, and the Court finds that this part of the analysis has been met.

Second, the proffered opinions must be assessed for reliability. Id. at 1180–81; Fed. R. Evid. 702(b)–(d). The opinions are reliable if the proponent of a qualified expert witness demonstrates to the Court that it is “more likely than not” that (a) “the expert’s scientific, technical, or other specialized knowledge will help the trier of fact to understand the evidence or to determine a fact or issue;” (b) the expert testimony is “based on sufficient facts or data;” (c) the expert testimony “is the product of reliable principles and methods;” and (d) “the expert’s opinion reflects a reliable application of the principles and methods to the facts of the case.” Fed. R. Evid. 702. To demonstrate the reliability of an opinion that is based solely on an expert’s experience, the expert “must explain how that experience leads to the conclusion

reached, why that experience is a sufficient basis for the opinion, and how that experience is reliably applied to the facts.” United States v. Medina-Copete, 757 F.3d 1092, 1104 (10th Cir. 2014) (quoting Fed. R. Evid. 702, advisory committee notes). Establishing reliability does not require showing that the expert’s testimony is indisputably correct. United States v. Pehrson, 65 F.4th 526, 540 (10th Cir. 2023); see also Goebel v. Denver & Rio Grande W. R.R. Co., 346 F.3d 987, 991 (10th Cir. 2003) (discussing how the opinion is tested against the standard of reliability, not correctness). Under Rule 702, a court must also ensure that the proffered testimony is relevant and will assist the trier of fact. See id. at 156; United States v. Rodriguez-Felix, 450 F.3d 1117, 1122–23 (10th Cir. 2006). “Relevant expert testimony must logically advance[ ] a material aspect of the case and be sufficiently tied to the facts of the case that it will aid the jury in resolving a factual dispute.” United States v. Garcia, 635 F.3d 472, 476 (10th

Cir. 2011) (quotations and citations omitted). In assessing whether expert testimony will assist the trier of fact, a court should also consider “whether the testimony ‘is within the juror’s common knowledge and experience,’ and ‘whether it will usurp the juror’s role of evaluating a witness’s credibility.’ ” Id. at 476–77 (quoting Rodriguez-Felix, 450 F.3d at 1123). Finally, Federal Rule of Evidence 403 permits a court to “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.” Fed. R. Evid. 403. III. ANALYSIS Plaintiff claims that Officer Ord shooting at him was an excessive use of force.

Claims of excessive force by law enforcement officers are analyzed under the Fourth Amendment’s “objective reasonableness” standard. Graham v. Connor, 490 U.S. 386, 388 (1989).

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