Malikah Asante-Chioke v. Nicholas Dowdle et al.

CourtDistrict Court, E.D. Louisiana
DecidedJanuary 5, 2026
Docket2:22-cv-04587
StatusUnknown

This text of Malikah Asante-Chioke v. Nicholas Dowdle et al. (Malikah Asante-Chioke v. Nicholas Dowdle et al.) is published on Counsel Stack Legal Research, covering District Court, E.D. Louisiana primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Malikah Asante-Chioke v. Nicholas Dowdle et al., (E.D. La. 2026).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF LOUISIANA MALIKAH ASANTE-CHIOKE CIVIL ACTION

VERSUS NO. 22-4587 NICHOLAS DOWDLE ET AL. SECTION: “J”(3) ORDER & REASONS Before the Court is a Motion to Exclude the Testimony of Thomas Martin (Rec.

Doc. 205) filed by Plaintiff Malikah Asante-Chioke. Defendants Officers Jonathon Downing, Gerard Duplessis, and Terry Durnin (“EJLD Defendants”) filed an opposition to the motion. (Rec. Doc. 213). Defendants Col. Lamar A. Davis and Nicholas Dowdle (“LSP Defendants”) also filed an opposition. (Rec. Doc. 218). Plaintiff filed a reply. (Rec. Doc. 232). Having considered the motion, the legal memoranda, the record, and the applicable law, the Court finds that the motion should be

GRANTED in part and DENIED in part. LEGAL STANDARD Federal Rule of Evidence 702 provides that a witness who is qualified as an expert may testify if: (1) the expert's “specialized knowledge will help the trier of

fact to understand the evidence or to determine a fact in issue”; (2) the expert's testimony “is based on sufficient facts or data”; (3) the expert's testimony “is the product of reliable principles and methods”; and (4) the principles and methods employed by the expert have been reliably applied to the facts of the case. Fed. R. Evid. 702. The United States Supreme Court's decision in Daubert v. Merrell Dow Pharmaceuticals, Inc., 509 U.S. 579 (1993), provides the analytical framework for determining whether expert testimony is admissible under Rule 702. Both scientific and nonscientific expert testimony are subject to

the Daubert framework, which requires trial courts to make a preliminary assessment of “whether the expert testimony is both reliable and relevant.” Burleson v. Tex. Dep't of Criminal Justice, 393 F.3d 577, 584 (5th Cir. 2004); see also Kumho Tire Co. v. Carmichael, 526 U.S. 137, 147 (1999). When expert testimony is challenged under Daubert, the party offering the expert's testimony bears the burden of proving its reliability and relevance by a

preponderance of the evidence. Moore v. Ashland Chem. Co., 151 F.3d 269, 276 (5th Cir. 1998). To be reliable, expert testimony must be based on “scientific knowledge,” meaning it must be “ground[ed] in the methods and procedures of science” and based on “more than subjective belief or unsupported speculation.” Daubert, 509 U.S. at 589-90. However, this rule does not require the testimony to be based on a scientific study, but allows testimony based on “personal experience” if, in the trial court's

view, there is a sufficient level of “intellectual rigor” underlying the testimony. Kumho Tire Co., 526 U.S. at 152. Indeed, “reliance upon extensive personal experience or specialized knowledge is an acceptable ground for the admission of expert testimony.” Derouen v. Hercules Liftboat Co., LLC, No. CV 13- 4805, 2015 WL 13528499, at *3 (E.D. La. Sept. 4, 2015). A number of nonexclusive factors may be relevant to the reliability analysis, including: (1) whether the technique at issue has been tested; (2) whether the technique has been subjected to peer review and publication; (3) the potential error

rate; (4) the existence and maintenance of standards controlling the technique's operation; and (5) whether the technique is generally accepted in the relevant scientific community. Burleson, 393 F.3d at 584. The reliability inquiry must remain flexible, however, as “not every Daubert factor will be applicable in every situation; and a court has discretion to consider other factors it deems relevant.” Guy v. Crown Equip. Corp., 394 F.3d 320, 325 (5th Cir. 2004); see also Runnels v. Tex. Children's

Hosp. Select Plan, 167 F. App'x 377, 381 (5th Cir. 2006) (“[A] trial judge has considerable leeway in determining how to test an expert's reliability.”). With respect to the relevancy prong, the proposed expert testimony must be relevant “not simply in the way all testimony must be relevant [pursuant to Rule 402], but also in the sense that the expert's proposed opinion would assist the trier of fact to understand or determine a fact in issue.” Bocanegra v. Vicmar Servs., Inc., 320 F.3d 581, 584 (5th Cir. 2003). Ultimately, a court should not allow its “gatekeeper”

role to supersede the traditional adversary system, or the jury's place within that system. Scordill v. Louisville Ladder Grp., LLC, No. 02-2565, 2003 WL 22427981 at *3 (E.D. La. Oct. 24, 2003). As the Supreme Court noted, “vigorous cross-examination, presentation of contrary evidence, and careful instruction on the burden of proof are the traditional and appropriate means of attacking shaky but admissible evidence.” Daubert, 509 U.S. at 596. Generally, questions relating to the basis and sources of an expert's opinion rather than its admissibility should be left for the jury's consideration. United States v. 14.38 Acres of Land, 80 F.3d 1074, 1077 (5th Cir. 1996) (citing Viterbo v. Dow Chemical Co., 826 F.2d 420, 422 (5th Cir. 1987)).

PARTIES’ ARGUMENTS AND DISCUSSION In his report, Mr. Martin offers the following conclusions and opinions: 1. There is a difference between what an officer can actually see during a real time event and what is captured on the officer’s body worn camera recording. 2. Each officer had a different visual perspective of Mr. Asante-Chioke as they fired at him. 3. It is not possible to identify the gun that fired bullet #15 using trajectory analysis, nor is it possible to determine exactly where in the sequence of the thirty-six shots that bullet #15 was fired. 4. Mr. Asante-Chioke's position of bending forward as he was falling forward is consistent with the back to front and upward trajectory of gunshot wound #15. 5. Given the wound path of bullet #15, and the position of Trooper Dowdle at the 3.67 frame . . . the trajectory of bullet #15 is not consistent with have [sic] been fired by Tpr. Dowdle at this frame. 6. The origination point (firearm) and sequence of each shot can not be determined with any scientific certainty using trajectory analysis. (Rec. Doc. 205-7, at 35). Plaintiff urges the Court to exclude Mr. Martin’s first two conclusions because they are factual statements that are unhelpful to the factfinder. (Rec. Doc. 205-1, at 5). Plaintiff then argues that the rest of Mr. Martin’s opinions are inadmissible because (1) Mr. Martin is unqualified, (2) his opinions lack factual support, (3) his methodology is unreliable, and (4) his opinions are unhelpful to the factfinder. Id. I. Mr. Martin’s First Two Conclusions Plaintiff seeks to exclude the first two conclusions and opinions from Mr. Martin’s report where he states, “There is a difference between what an officer can

actually see during a real time event and what is captured on the officer’s body worn camera recording.” (Rec. Doc. 205-1, at 3). And “[e]ach officer had a different visual perspective of Mr.

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Related

Moore v. Ashland Chemical Inc.
151 F.3d 269 (Fifth Circuit, 1998)
Bocanegra v. Vicmar Services, Inc.
320 F.3d 581 (Fifth Circuit, 2003)
Burleson v. Texas Department of Criminal Justice
393 F.3d 577 (Fifth Circuit, 2004)
Guy v. Crown Equipment Corp.
394 F.3d 320 (Fifth Circuit, 2004)
Runnels v. Texas Children's Hospital Select Plan
167 F. App'x 377 (Fifth Circuit, 2006)
United States v. McGinnis
201 F. App'x 246 (Fifth Circuit, 2006)
Daubert v. Merrell Dow Pharmaceuticals, Inc.
509 U.S. 579 (Supreme Court, 1993)
Kumho Tire Co. v. Carmichael
526 U.S. 137 (Supreme Court, 1999)
Roque v. Harvel
993 F.3d 325 (Fifth Circuit, 2021)

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