Nicole Bolder v. Officer Thomas Brecker

CourtDistrict Court, E.D. Pennsylvania
DecidedOctober 31, 2025
Docket5:23-cv-05138
StatusUnknown

This text of Nicole Bolder v. Officer Thomas Brecker (Nicole Bolder v. Officer Thomas Brecker) is published on Counsel Stack Legal Research, covering District Court, E.D. Pennsylvania primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Nicole Bolder v. Officer Thomas Brecker, (E.D. Pa. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA __________________________________________

NICOLE BOLDER, : Plaintiff, : : v. : Civil No. 5:23-cv-05138-JMG : OFFICER THOMAS BRECKER, : Defendant. : __________________________________________

MEMORANDUM OPINION

GALLAGHER, J. October 31, 2025

I. OVERVIEW Plaintiff sued Defendant over an incident that occurred on January 20, 2022, alleging racial discrimination, unlawful seizure, and several state law claims. The parties seek to introduce expert testimony to assist the jury in determining whether Defendant acted in a discriminatory manner and in assessing Plaintiff’s psychological damages. Both parties produced expert reports after the time set forth in the scheduling orders, both parties filed motions to strike for late disclosures, and both parties filed untimely Daubert motions. The Court will address the motions in one omnibus opinion. For the reasons that follow, the Court GRANTS Defendant’s motion to strike Plaintiff’s Expert Pastor John Peyton, Ph.D., and DENIES the remaining motions as untimely. Upon the Court’s sua sponte Daubert analysis, the Court finds that Plaintiff’s Expert Larry Rotenberg, M.D. is PARTIALLY PRECLUDED from testifying at trial, Plaintiff’s Expert Darrin Porcher, Ed.D. is PRECLUDED from testifying at trial, and Defense Expert Stephen Mechanick, M.D. is ADMITTED to testify at trial. II. BACKGROUND On January 20, 2022, Plaintiff Nicole Bolder locked herself out of her car in the Walmart parking lot in Caernarvon Township, Pennsylvania. Initially, she received help from Defendant Officer Thomas Brecker, who was responding to a 911 hang-up call at Walmart. Defendant offered

to call a towing company to unlock Plaintiff’s car. Plaintiff asked Defendant if the tow company would “bill” her, to which Defendant said yes. The towing company, Creative Customs, advised that it could send a truck to Walmart. When the tow truck arrived, Defendant left the scene. After unlocking her car, the tow truck driver asked Plaintiff for payment. Plaintiff explained that she did not have money on her, but Defendant informed her that she would be billed at a later date. The tow truck driver advised that was incorrect; payment was due immediately. The tow truck driver called the owner of Creative Customs to report the situation. The owner then called Defendant and told him that Plaintiff did not have money to pay for the lock-out service. Defendant returned to Walmart. He asked Plaintiff what could be done to resolve this situation, whether she had a job, or whether she knew anyone who could lend her $100. Despite

Plaintiff explaining that she was all by herself, Defendant told her, “I suggest you call somebody.” When Plaintiff said she did not understand and that she was told the tow truck company would bill her, Defendant angrily responded, “You owe me money, I’m going to pay for it ok, but you owe me money. If you do not pay me, I will arrest you for theft.” Using a similar tone of voice that he used with Plaintiff, Defendant then ordered the tow truck driver to follow him, so he could give the driver $100 for the lock-out service. The tow driver reported that Defendant pulled into the ATM line facing the wrong direction and pinned three other vehicles in line. After Defendant’s card declined, Defendant told the tow truck driver to follow him to Wawa. Defendant drove at a high rate of speed on Route 23, going through traffic lights with his emergency lights activated. After Defendant paid the tow truck driver, he returned to Walmart. Plaintiff was still there, crying and with cash in her hand. Defendant repeatedly apologized to her and refused Plaintiff’s

money, as the township would be reimbursing him. Plaintiff Nicole Bolder brought claims against Defendant Officer Thomas Brecker, alleging racial discrimination, unlawful seizure, and supplemental claims for false imprisonment, intentional infliction of emotional distress, and assault. The parties asked the Court for several extensions throughout the litigation, and the Court obliged. Fact and expert discovery closed on May 16, 2025, and summary judgment and Daubert motions were due on July 28, 2025. See First Am. Scheduling Order (ECF No. 43); Second Am. Scheduling Order (ECF No. 45). Defendant filed a motion for summary judgment on the due date, which is still pending with the Court. Neither party filed Daubert motions. On October 1, 2025, Defendant filed three motions: two motions to strike and/or motions

in limine, and one motion in limine. See generally Def.’s Mot. to Strike and/or Mot. in Lim. to Preclude Larry Rotenberg (ECF No. 59); Def.’s Mot. to Strike and/or Mot. in Lim. to Preclude John Peyton (ECF No. 58); Def.’s Mot. in Lim. (ECF No. 57). Plaintiff filed her motion in limine on October 13, 2025. See generally Pl.’s Mot. in Lim. (ECF No. 65). Both parties sought to preclude experts and challenged untimely expert disclosures. In light of the Court setting the deadline for Daubert motions as July 28, 2025, and expert disclosures far before that, the Court requested the parties confirm that they were: (1) filing Daubert motions two months late, and (2) challenging the admissibility of the other’s witnesses based on untimely disclosure. If so, the Court requested the parties show cause why each untimely disclosure should be excused, and why the Court should consider the merits of the untimely disclosures. Both parties agreed to waive the untimeliness arguments against each other, except with respect to Plaintiff’s Expert Pastor John Peyton, Ph.D. Additionally, Plaintiff argued that Pastor

Peyton’s testimony was not late, did not prejudice Defendant, and exclusion would be a “drastic sanction.” See Pl.’s Resp. to Req. to Show Cause, at 2-5 (ECF No. 73). Plaintiff further argued that she did not receive Dr. Mechanick’s report until September 9, 2025 and could not file a timely Daubert motion. Id. at 6. Defendant denied altogether that he filed Daubert motions. See Def.’s Resp. to Req. to Show Cause, at 2 (ECF No. 72). III. LEGAL STANDARD “Under the Federal Rules of Evidence, a trial judge acts as a gatekeeper to ensure that any and all expert testimony or evidence is not only relevant, but also reliable.” Pineda v. Ford Motor Co., 520 F.3d 237, 243 (3d Cir. 2008) (internal quotations omitted). “Rule 702 has a liberal policy of admissibility,” so long as an expert meets the requirements of qualification, reliability, and fit.

Nat’l Fire & Marine Ins. Co. v. Newtown Square, LLC, No. CV 21-5397, 2024 WL 1683609, at *2 (E.D. Pa. Apr. 18, 2024) (citing Kannankeril v. Terminix Int’l, Inc., 128 F.3d 802, 806 (3d Cir. 1997), as amended (Dec. 12, 1997)); J.L. v. Lower Merion Sch. Dist., No. CV 20-1416-KSM, 2024 WL 5227410, at *3 (E.D. Pa. Dec. 26, 2024). Rule 702 was amended in 2023 and currently reads: A witness who is qualified as an expert by knowledge, skill, experience, training, or education may testify in the form of an opinion or otherwise if the proponent 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 in issue; (b) the testimony is based on sufficient facts or data; (c) the 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.

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Nicole Bolder v. Officer Thomas Brecker, Counsel Stack Legal Research, https://law.counselstack.com/opinion/nicole-bolder-v-officer-thomas-brecker-paed-2025.