Virginia State Conference NAACP et al. v. County School Board of Shenandoah County

CourtDistrict Court, W.D. Virginia
DecidedDecember 8, 2025
Docket5:24-cv-00040
StatusUnknown

This text of Virginia State Conference NAACP et al. v. County School Board of Shenandoah County (Virginia State Conference NAACP et al. v. County School Board of Shenandoah County) is published on Counsel Stack Legal Research, covering District Court, W.D. Virginia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Virginia State Conference NAACP et al. v. County School Board of Shenandoah County, (W.D. Va. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT Re eee □□□ FOR THE WESTERN DISTRICT OF VIRGINIA FILED HARRISONBURG DIVISION December 08, 2025 LAURA A. AUSTIN, CLI Virginia State Conference NAACP ) a aes: et al., ) ) Case No, 5:24-cv-040 Plaintiffs, ) ) v. ) ) County School Board of Shenandoah ) By: Michael F. Urbanski County, ) Senior United States District Judge ) Defendant. )

MEMORANDUM OPINION Plaintiffs have filed motions to exclude the testimony of defendant’s experts Dr. Wanjiru Njoya, Gibson Kerr, and H.K. Edgerton. ECF Nos. 193, 197, 203. Defendant has filed a motion to exclude some of the testimony of plaintiffs expert Dr. Adiaha Spinks- Franklin. ECF No. 200.' A bench trial is scheduled to commence in this case on December 11, 2025. The court has reviewed the motions in limine, expert reports, depositions, and briefing. For the following reasons, the court GRANTS plaintiffs’ motion in limine regarding the proposed expert testimony of Dr. Njoya and Mr. Edgerton. The court GRANTS in PART and DENIES in PART the motion in limine regarding the proposed expert testimony

1 Defendant also moved to exclude some of the testimony of two other experts offered by plaintiffs, that of Brig. Gen. Ty Seidule and Dr. Brian Daugherity. ECF No. 200. However, defendant withdrew its objection to these experts’ testimony after plaintiffs agreed that they would not ask Seidule to offer an opinion as to whether restoring the original name of the schocl was cruel to Black students and would not offer Daugherity’s opinion as evidence of the 2024 school board’s intent. See Pls.’ Opp’n to Def.’s Mot. in Limine, ECF No. 204 at 3, and Def’s Reply in Supp. of Mot. in Limine, ECF No. 209 at 7 n.2.

of Mr. Kerr, Defendant’s motion in limine regarding the proposed expert testimony of Dr. Spinks-Franklin is DENIED. I. The admissibility of expert reports and their proposed testimony at trial is governed by Federal Rule of Evidence 702.2 Rule 702’s prescriptions are guided by the Supreme Court’s decisions in Daubert v. Merrell Dow Pharms. Inc., 509 U.S. 579 (1993), and Kumho Tire Co., Ltd. v. Carmichael, 526 U.S. 137 (1999). In Daubert, the Court explained that the “trial judge must ensure that any and all scientific testimony or evidence admitted is not only relevant, but reliable.” 509 U.S. at 589. Under Rule 702, “expert testimony which does not relate to any issue in the case is not relevant and, ergo, non-helpful” to the trier of fact. Id. at 591. In Kumho Tire, 526 U.S. at 141, the Supreme Court made clear that these principles apply to all proposed expert witnesses. The language of Rule 702 “‘makes no relevant distinction between ‘scientific’ knowledge and ‘technical’ or ‘other specialized’ knowledge. It makes clear that any such knowledge might become the subject of expert testimony.” Id. at 147. An expert may be qualified based on experience. United States v. Wilson, 484 F.3d 267, 274 (4th Cir. 2007) (citing Fed. R. Evid. 702 advisory committee’s note). Experiential expert testimony does not “rely on anything like a scientific method,” id., (quoting the advisory

2 Rule 702 states: 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: (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 has reliably applied the principles and methods to the facts of the case.

committee note), making a district court’s task in examining the reliability “somewhat more opaque.” Id. “[T]he district court must nonetheless require an experiential witness to ‘explain how [his] experience leads to the conclusion reached, why [his] experience is a sufficient basis for the opinion, and how [his] experience is reliably applied to the facts.” Id. (quoting the advisory committee note). “The more subjective and controversial the expert’s inquiry, the more likely the testimony should be excluded as unreliable.” Fed. R. Evid. 702 advisory committee’s note (citing O’Connor v. Commonwealth Edison Co., B F.3d 1090 (7th Cir. 1994)). “The question of whether a witness is qualified to testify is context-driven and can only be determined by the nature of the opinion he offers.” RG Steel Sparrows Point, LLC v. Kinder Morgan Bulk Terminals, Inc., 609 F. App’x 731, 738 (4th Cir. 2015). “[Cjourts should be conscious of two guiding, and sometimes competing, principles[:] Rule 702 was intended to liberalize the introduction of relevant expert evidence [and] expert witnesses have the potential to be both powerful and quite misleading.” Hickerson v. Yamaha Motor Corp., 882 F.3d 476, 481 (4th Cir. 2018) (citing Westberry v. Gislaved Gummi AB, 178 F.3d 257, 261 (4th Cir. 1999)). “[A] trial judge has wide discretion in the admission or exclusion of opinion evidence. This discretion, expansive in all events, is at maximum girth in the context of a bench trial.” Chicago Title Ins. Co. v. IMG Exeter Assocs. Ltd. P’ship, No. 92-1440, 1993 WL 297392, at *4 n.6 (4th Cir. Feb. 8, 1993) (citing Northern Heel Corp. v. Compo Industries, 851 F.2d 456, 468 (1st Cir. 1988)); see also United States v. Dorsey, 45 F.3d 809, 814 (4th Cir, 1995).

The court is obligated to act as a gatekeeper for expert opinions, but the “traditional and appropriate means” of challenging expert testimony are “vigorous cross-examination, presentation of contrary evidence, and careful instruction on the burden of proof....” Glass v. Anne Arundel Caty., 38 F. Supp. 3d 705, 714 (D. Md. 2014), aff'd, 716 F. App’x 179 (4th Cir. 2018). Accordingly, “[t]he court need not determine that the expert testimony is irrefutable or certainly correct.” United States v. Moreland, 437 F.3d 424, 431 (4th Cir. 2006), overruled on other grounds, U.S. v. Foote, 784 F.3d 931 (4th Cir, 2015). “The gatekeeping function of the court is relaxed where a bench trial is to be conducted ... because the court is better equipped than a jury to weigh the probative value of expert evidence.” Traxys v. North America, LLC, v. Concept Mining, Inc., 808 F.Supp.2d 851, 853 (W.D. Va. 2011). The gatekeeper doctrine was designed to protect juries and is largely irrelevant in the context of a bench trial. S. Indus. Contractors, LLC v. O’Brien & Gere of N. Am., D.S.C. No. 2:19-CV-1691, 2021 WL 1244872, at *1 (D.S.C. Apr. 2, 2021) (quoting Deal y. Hamilton Cnty. Bd. of Educ., 392 F.3d 840, 852 (6th Cir. 2004), and United States v. Brown, 415 F.3d 1257, 1269 (11th Cir. 2005)) (cleaned up).

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Bluebook (online)
Virginia State Conference NAACP et al. v. County School Board of Shenandoah County, Counsel Stack Legal Research, https://law.counselstack.com/opinion/virginia-state-conference-naacp-et-al-v-county-school-board-of-shenandoah-vawd-2025.