Van Loo v. United States

CourtDistrict Court, W.D. Washington
DecidedMarch 4, 2025
Docket3:23-cv-05618
StatusUnknown

This text of Van Loo v. United States (Van Loo v. United States) is published on Counsel Stack Legal Research, covering District Court, W.D. Washington primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Van Loo v. United States, (W.D. Wash. 2025).

Opinion

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5 6 7 UNITED STATES DISTRICT COURT 8 WESTERN DISTRICT OF WASHINGTON AT TACOMA 9 10 CINDY VAN LOO, CASE NO. 3:23-cv-05618-DGE 11 Plaintiff, ORDER GRANTING IN PART 12 v. AND DENYING IN PART MOTIONS TO EXCLUDE (DKT. 13 UNITED STATES OF AMERICA et al., NOS. 120, 122) 14 Defendant. 15

16 I INTRODUCTION 17 Before the Court is the Federal Defendants’ motion to exclude Plaintiff’s experts Joel 18 Newman, Kenton Wong, and Russell Hicks (Dkt. No. 120) and Plaintiff’s motion to exclude 19 Defendants’ expert Paul Massock (Dkt. No. 122.) The Court GRANTS the motions in part and 20 DENIES in part. 21 II BACKGROUND 22 This case concerns the shooting death of Michael Reinoehl by a United States Marshals 23 Service (“USMS”) task force. (Dkt. No. 89 at 3.) At issue is the testimony of the experts named 24 1 above, and the admissibility of a 3D visualization of the scene of the shooting. Wong is a 2 forensic scientist and licensed crime scene investigator. (Dkt. No. 140 at 2.) Newman holds 3 bachelor’s and master’s degrees in art and has six years of experience designing 3D 4 visualizations of crime scenes; he works at a design firm called Fat Pencil Studio. (Id. at 3; Dkt.

5 No. 144-1 at 2.) Wong and Newman were involved in creation of the 3D model—though the 6 extent of their respective contributions is disputed. Defendants argue that Wong does not offer 7 an opinion based on independent analysis and that he did not contribute his forensic expertise to 8 the 3D model’s creation. (See Dkt. No. 120 at 9–12.) Likewise, Defendants argue that Newman 9 does not independently possess the qualifications to create a crime scene reconstruction, and that 10 he employed guesswork in positioning figures in the model. (Id. at 7–9.) Hicks is a law 11 enforcement practices expert, but Defendants argue that his experience is limited to local 12 policing and that he is not qualified to opine on or did not consider relevant USMS practices. 13 (Id. at 12–14.) 14 Plaintiff argues that the 3D visualization is admissible as either substantive or

15 demonstrative evidence, that Wong and Newman used reliable methods, and that it is improper 16 to view their qualifications independently when they worked collaboratively. (Dkt. No. 140 at 17 6–11.) As to Hicks, Plaintiff argues that he did not fail to consider any pertinent evidence, that 18 he does possess experience with federal task forces, and that the specific jurisdictions Hicks 19 worked in are not relevant to his qualifications. (Id. at 11–13.) Further, Plaintiff notes that 20 Defendants were bound by local use of force policies while serving as members of the federal 21 task force, so testimony as to local use of force policies is relevant. (Id. at 13–14.) 22 Plaintiff seeks to exclude Massock on the basis that he offers only one opinion, which is 23 that the use of force by the Defendant officers was reasonable, which is a conclusion that only

24 1 the trier of fact may decide. (See Dkt. No. 122.) Defendants argue that Massock’s opinions are 2 not limited to reasonableness and are not legal conclusions, but ask that if the Court were to 3 exclude his opinion on reasonableness that his testimony otherwise be allowed. (See Dkt. No. 4 135 at 7–10 & n.3.)

5 III DISCUSSION 6 A. Legal Standard 7 1. Expert Testimony 8 Admissibility of expert testimony is governed by Federal Rule of Evidence 702 and 9 Daubert v. Merrell Dow Pharmaceuticals, Inc., 509 U.S. 579 (1993). Under Rule 702, the 10 proponent must show it is “more likely than not” that: 11 (a) the expert's scientific, technical, or other specialized knowledge will help the trier of 12 fact to understand the evidence or to determine a fact in issue; 13 (b) the testimony is based on sufficient facts or data; 14 (c) the testimony is the product of reliable principles and methods; and

15 (d) the expert’s opinion reflects a reliable application of the principles and methods to the 16 facts of the case. 17 Fed. R. Evid. 702. The first prong of Rule 702 “goes primarily to relevance.” Daubert, 509 U.S. 18 at 591. Additionally, Daubert provides a non-exhaustive list of factors for trial courts to 19 consider, including 1) whether the expert’s technique or methodology is testable, 2) whether it 20 has been subject to peer review, 3) “known or potential rate of error,” 4) “existence and 21 maintenance of standards controlling the technique’s operation,” and 5) “general acceptance.” 22 Id. at 593–594. 23

24 1 In this inquiry, the Court’s role is to act as a gatekeeper and “to ensure the reliability and 2 relevancy of expert testimony.” Kumho Tire Co. v. Carmichael, 526 U.S. 137, 152 (1999). “The 3 test for reliability, however, ‘is not the correctness of the expert’s conclusions but the soundness 4 of his methodology.’ And, reliable testimony must nevertheless be helpful.” Stilwell v. Smith &

5 Nephew, Inc., 482 F.3d 1187, 1192 (9th Cir. 2007) (quoting Daubert v. Merrell Dow Pharms., 6 Inc., 43 F.3d 1311, 1318 (9th Cir.1995)) (internal citation omitted). The Ninth Circuit has 7 cautioned district courts against weighing expert “conclusions or assum[ing] a factfinding role.” 8 Elosu v. Middlefork Ranch Inc., 26 F.4th 1017, 1020 (9th Cir. 2022). The Court “is not tasked 9 with deciding whether the expert is right or wrong, just whether his testimony has substance such 10 that it would be helpful to a jury.” Alaska Rent-A-Car, Inc. v. Avis Budget Grp., Inc., 738 F.3d 11 960, 969–970 (9th Cir. 2013). To determine the helpfulness of an expert’s testimony, courts 12 evaluate whether the testimony makes a fact of consequence more or less probable. Hemmings 13 v. Tidyman’s Inc., 285 F.3d 1174, 1184 (9th Cir. 2002); Daubert, 509 U.S. at 591. 14 2. Demonstrative Evidence and Visual Aids: Definition and Admissibility

15 Plaintiff argues in the alternative that the 3D model may be offered as “demonstrative 16 evidence.” (Dkt. No. 140 at 6.) There is not a single agreed upon definition of the term 17 “demonstrative evidence,” but the Court understands its meaning here to be “an object or 18 document that could be displayed to the jurors to help them understand the substantive evidence 19 (testimony or other objects or documents) by interpreting, summarizing, or explaining it, but that 20 would not be available during deliberations.” Baugh ex rel. Baugh v. Cuprum S.A. de C.V., 730 21 F.3d 701, 706 (7th Cir. 2013). Demonstrative exhibits need not be admitted into evidence, but a 22 jury may not have access to them during deliberations. Id. at 708; see also United States v. Cox, 23

24 1 633 F.2d 871, 874 (9th Cir. 1980). Commentary to the Federal Rules of Evidence takes a 2 generally favorable view of visual aids, while also urging some caution: 3 In order to explain or prove how a disputed event occurred, a party may find it helpful to demonstrate the event in court, or to provide a videotaped or even a computerized 4 recreation of the disputed event. Such demonstrative evidence is regulated by the trial court under Rule 403.

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Related

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)
United States v. Gregory W. T. Cox
633 F.2d 871 (Ninth Circuit, 1980)
Lisa Stilwell v. Smith & Nephew, Inc., a Corporation
482 F.3d 1187 (Ninth Circuit, 2007)
United States v. Clemens
738 F.3d 1 (First Circuit, 2013)
Hinkle v. City of Clarksburg
81 F.3d 416 (Fourth Circuit, 1996)
Maria Elosu v. Middlefork Ranch Incorporated
26 F.4th 1017 (Ninth Circuit, 2022)
Scott v. Ross
140 F.3d 1275 (Ninth Circuit, 1998)

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Van Loo v. United States, Counsel Stack Legal Research, https://law.counselstack.com/opinion/van-loo-v-united-states-wawd-2025.