Riaz v. Henry

CourtDistrict Court, E.D. California
DecidedMarch 28, 2025
Docket1:21-cv-00911
StatusUnknown

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

Bluebook
Riaz v. Henry, (E.D. Cal. 2025).

Opinion

1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 EASTERN DISTRICT OF CALIFORNIA 10 11 SAMREEN RIAZ No. 1:21-cv-00911-KES-SKO 12 Plaintiff, ORDER GRANTING IN PART AND DENYING IN PART DEFENDANTS’ JOINT 13 v. MOTION IN LIMINE AS TO PLAINTIFF’S EXPERT DR. JULIE ARMSTRONG 14 NATHAN HENRY, et al., Doc. 54 15 Defendants. 16 17 This is a civil rights and state tort action concerning defendants’ detention of plaintiff 18 Samreen Riaz on August 12, 2020, pursuant to California Welfare & Institutions Code § 5150. 19 This action is set for trial on plaintiff’s claims for: (1) unlawful seizure, detention, and 20 confinement under the Fourth Amendment, in violation of 42 U.S.C. § 1983, against defendants 21 Henry, Canto, Alvarez, and Ceballos; (2 and 3) Monell liability under 42 U.S.C. § 1983 against 22 defendants City of Visalia and County of Tulare; and (4) negligence, (5) false arrest, (6) battery, 23 and (7) intentional infliction of emotional distress against defendants Henry, Canto, and Alvarez. 24 The Court held oral argument on defendants’ joint motions in limine on March 17, 2025. 25 Docs. 54, 63. The Court took under submission defendants’ motion in limine to exclude the 26 testimony of plaintiff’s expert witness, Dr. Julie Armstrong.1 See Doc. 63. For the reasons set 27 1 The Court’s rulings on the remaining motions in limine were noted on the record at the hearing. 28 See Doc. 63. 1 forth below, defendants’ motion in limine to exclude Dr. Armstrong’s testimony is granted in part 2 and denied in part. 3 I. LEGAL STANDARD 4 A witness who has been qualified as an expert by knowledge, skill, experience, training, 5 or education may give an opinion on scientific, technical, or otherwise specialized topics if (1) the 6 expert’s scientific, technical, or other special knowledge will help the trier of fact understand the 7 evidence or determine a fact in issue, (2) the testimony is based upon sufficient facts or data, 8 (3) the testimony is the product of reliable principles and methods, and (4) the witness has applied 9 the principles and methods reliably to the facts of the case. Fed. R. Evid. 702; City of Pomona v. 10 SQM N. Am. Corp., 750 F.3d 1036, 1043–44 (9th Cir. 2014). The Court serves as a gatekeeper 11 by “ensuring that an expert’s testimony both rests on a reliable foundation and is relevant to the 12 task at hand.” Daubert v. Merrell Dow Pharms., Inc., 509 U.S. 579, 597 (1993). 13 “Scientific evidence is reliable if it is based on an assertion that is grounded in methods of 14 science—the focus is on principles and methodology, not conclusions.” Metabolife Int’l, Inc. v. 15 Wornick, 264 F.3d 832, 841 (9th Cir. 2001). The test of reliability is flexible, and the Court 16 “must assess the expert’s reasoning or methodology, using as appropriate criteria such as 17 testability, publication in peer-reviewed literature, known or potential error rate, and general 18 acceptance.” City of Pomona, 750 F.3d at 1044. Other factors that might be considered include 19 whether an expert has unjustifiably extrapolated from an accepted premise to an unfounded 20 conclusion, see General Elec. Co. v. Joiner, 522 U.S. 136, 146 (1997), or whether an expert has 21 adequately accounted for obvious alternative explanations, see Claar v. Burlington Northern R. 22 Co., 29 F.3d 499, 502 (9th Cir. 1994). 23 The judge should “screen the jury from unreliable nonsense opinions, but not exclude 24 opinions merely because they are impeachable.” Alaska Rent-A-Car, Inc. v. Avis Budget Grp., 25 Inc., 738 F.3d 960, 969 (9th Cir. 2013). Simply put, “[t]he district court is not tasked with 26 deciding whether the expert is right or wrong, just whether his testimony has substance such that 27 it would be helpful to a jury.” Id. at 969–70. “Shaky but admissible evidence is to be attacked by 28 cross examination, contrary evidence, and attention to the burden of proof, not exclusion.” 1 Primiano v. Cook, 598 F.3d 558, 564 (9th Cir. 2010). The Court has discretion to decide how to 2 test an expert’s reliability based on the type of expert testimony offered. City of Pomona, 750 3 F.3d at 1045. The test is the soundness of the methodology, with the fact finder weighing 4 testimony that meets the threshold established by Rule 702. Id. The party offering the expert 5 bears the burden of establishing that Rule 702 is satisfied. Daubert, 509 U.S. at 593 n. 10. 6 II. DISCUSSION 7 Defendants move to exclude plaintiff’s expert, Dr. Armstrong, on three grounds: (1) Dr. 8 Armstrong allegedly lacks the required qualifications, knowledge, experience or education to 9 render opinions in this matter; (2) Dr. Armstrong failed to consider all relevant information in 10 reaching her opinions; and (3) Dr. Armstrong rendered no opinion as to plaintiff’s mental state 11 following her arrest and detention, and therefore may not testify to any psychological harm 12 caused to plaintiff by defendants’ alleged conduct. Doc. 54. Plaintiff opposes the first and 13 second grounds of the motion, arguing that Dr. Armstrong is qualified given her more than 30 14 years of experience in providing psychological assessments, and that she sufficiently reviewed the 15 relevant documentation to enable her to make an informed assessment. Doc. 58. Plaintiff does 16 not oppose the third ground of the motion. 17 1. Dr. Armstrong’s Qualifications 18 As further clarified at the motion in limine hearing, plaintiff seeks to have Dr. Armstrong 19 testify as to whether, based on the information available at the time, plaintiff (a) was a threat to 20 herself, (b) was a threat to others, or (c) was gravely disabled, such that she could be subjected to 21 a 5150 hold. Doc. 54–2 at 2–3. Rule 702 “contemplates a broad conception of expert 22 qualifications.” Hangarter v. Provident Life & Acc. Ins. Co., 373 F.3d 998, 1018 (9th Cir. 2004) 23 (emphasis omitted). However, while an expert need not be officially credentialed in the specific 24 matter under dispute, she must nonetheless have the requisite “knowledge, skill, experience, 25 training, or education” in the field in which her opinions are based. See U.S. v. Garcia, 7 F.3d 26 885, 889–90 (9th Cir. 1993); Fed. R. Evid. 702. 27 In her curriculum vitae, Dr. Armstrong’s profile states she is a licensed psychologist and 28 clinical nurse specialist, with more than 30 years of experience providing psychological 1 assessments and expert witness consulting. Id. at 7–10. Dr. Armstrong holds a Doctor of 2 Psychology (PsyD) degree and master’s and bachelor’s degrees in nursing. Id. at 7. 3 Dr. Armstrong taught psychiatry and biobehavioral sciences for six years at the UCLA School of 4 Medicine and also held faculty positions at two other universities. Id. at 9. Dr. Armstrong has 5 also published or presented psychology research. Id.

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