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700 KB
Extraction Summary
9
People
6
Organizations
1
Locations
3
Events
2
Relationships
8
Quotes
Document Information
Type:
Legal document
File Size:
700 KB
Summary
This legal document, a page from a court filing, discusses the standards for admitting expert testimony in court. It argues that a district court has broad discretion in determining the reliability of such testimony and that it must also be relevant, concerning matters beyond the understanding of an average juror. The document cites several precedents, focusing on cases where courts admitted expert testimony on the psychological dynamics between perpetrators and victims of sex crimes, such as the 'pimp-prostitute relationship' and 'trauma bonding'.
People (9)
| Name | Role | Context |
|---|---|---|
| Requena |
Party in the case United States v. Requena, 980 F.3d 30, 47 (2d Cir. 2020).
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| Williams |
Party in the case Williams, 506 F.3d at 161.
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| Barnes |
Party in the case United States v. Barnes, 411 F. App’x 365, 370 (2d Cir. 2011).
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| Weinstein |
Author of Weinstein’s Federal Evidence § 702.02 [2] (2d ed. 2006).
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| Torres |
Party in the case United States v. Torres, No. 20 Cr. 608 (DLC), 2021 WL 1947503, at *6 (S.D.N.Y. May 13, 2021).
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| Mejia |
Party in the case United States v. Mejia, 545 F.3d 179, 194 (2d Cir. 2008).
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| Faulkner |
Party in the case Faulkner v. Arista Records LLC, 46 F. Sup. 3d 365, 375 (S.D.N.Y. 2014).
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| Kidd |
Party in the case United States v. Kidd, 385 F. Supp. 3d 259 (S.D.N.Y. 2019).
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| Daubert |
Referenced in the context of a "Daubert challenge," a legal challenge to the admissibility of expert witness testimony.
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Organizations (6)
| Name | Type | Context |
|---|---|---|
| Fed. R. Evid. 702 Advisory Committee | government agency |
Cited in reference to the committee's notes on Federal Rule of Evidence 702.
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| Kumho Tire | company |
Party in the case Kumho Tire, 526 U.S. at 142.
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| Arista Records LLC | company |
Party in the case Faulkner v. Arista Records LLC, 46 F. Sup. 3d 365, 375 (S.D.N.Y. 2014).
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| United States Government | government agency |
Referenced as a party in several court cases (e.g., United States v. Requena) and as "the Government" which gave noti...
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| S.D.N.Y. | court |
Southern District of New York, a federal district court cited multiple times.
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| 2d Cir. | court |
United States Court of Appeals for the Second Circuit, cited multiple times.
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Timeline (3 events)
2019
In the case United States v. Kidd, the Government gave notice of expert testimony on "the psychology of the pimp-prostitute relationship."
S.D.N.Y.
Locations (1)
| Location | Context |
|---|---|
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The Southern District of New York is mentioned as the jurisdiction for several cited cases.
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Relationships (2)
Perpetrators of sex crimes
→
psychological
→
Victims of sex crimes
The document states that courts have frequently admitted expert testimony on the psychological relationship between perpetrators and victims of sex crimes.
Pimp
→
psychological
→
Prostitute
The document cites a case where the Government gave notice of expert testimony on "the psychology of the pimp-prostitute relationship," including concepts like "trauma bonding."
Key Quotes (8)
"[T]he law grants a district court the same broad latitude when it decides how to determine reliability as it enjoys in respect to its ultimate reliability determination."Source
— Kumho Tire, 526 U.S. at 142
(Describing the court's discretion in assessing the reliability of expert testimony.)
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Quote #1
"This is particularly true if, at the time that the expert testimony is presented to the jury, a sufficient basis for allowing the testimony is on the record."Source
— Williams, 506 F.3d at 161
(Regarding the conditions under which a court can exercise its gatekeeping function for expert testimony.)
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Quote #2
"concern matters that the average juror is not capable of understanding on his or her own."Source
— United States v. Mejia, 545 F.3d 179, 194
(Defining the type of matters that require expert testimony for relevance.)
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Quote #3
"Weighing whether the expert testimony assists the trier of fact goes primarily to relevance."Source
— Faulkner v. Arista Records LLC, 46 F. Sup. 3d 365, 375
(Explaining the standard for determining the relevance of expert testimony.)
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Quote #4
"the psychology of the pimp-prostitute relationship,"Source
— United States v. Kidd, 385 F. Supp. 3d 259
(The subject of expert testimony given notice by the Government in the Kidd case.)
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Quote #5
"trauma bonding."Source
— United States v. Kidd, 385 F. Supp. 3d 259
(A concept included in the expert testimony on the psychology of the pimp-prostitute relationship.)
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Quote #6
"studies or empirical data"Source
— Defendant in United States v. Kidd
(The basis that the defendant argued was lacking in the expert's testimony, making it unreliable.)
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Quote #7
"be assessed for reliability."Source
— Defendant in United States v. Kidd
(The defendant's argument that the expert testimony could not be assessed for reliability because it was not based on studies or data.)
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Quote #8
Full Extracted Text
Complete text extracted from the document (2,073 characters)
Case 1:20-cr-00330-PAE Document 397 Filed 10/29/21 Page 9 of 84
(S.D.N.Y. 2012) (citing Fed. R. Evid. 702 Advisory Committee’s Notes (2000 Amendments)).
“[T]he law grants a district court the same broad latitude when it decides how to determine
reliability as it enjoys in respect to its ultimate reliability determination.” Kumho Tire, 526 U.S.
at 142 (emphasis in original); see United States v. Requena, 980 F.3d 30, 47 (2d Cir. 2020). Thus
a district court may properly exercise its gatekeeping function without the “formality of a separate
hearing[.]” Williams, 506 F.3d at 161; see also United States v. Barnes, 411 F. App’x 365, 370
(2d Cir. 2011) (summary order). “This is particularly true if, at the time that the expert testimony
is presented to the jury, a sufficient basis for allowing the testimony is on the record.” Williams,
506 F.3d at 161 (citing 4 Weinstein’s Federal Evidence § 702.02 [2] (2d ed. 2006)).
Finally, even if the expert testimony is reliable, it must also be relevant. See, e.g., United
States v. Torres, No. 20 Cr. 608 (DLC), 2021 WL 1947503, at *6 (S.D.N.Y. May 13, 2021). In
this context, the testimony must “concern matters that the average juror is not capable of
understanding on his or her own.” United States v. Mejia, 545 F.3d 179, 194 (2d Cir. 2008); see
Faulkner v. Arista Records LLC, 46 F. Sup. 3d 365, 375 (S.D.N.Y. 2014) (“Weighing whether the
expert testimony assists the trier of fact goes primarily to relevance.”).
Courts have frequently admitted expert testimony on the psychological relationship
between perpetrators and victims of sex crimes. For instance, in United States v. Kidd, 385 F.
Supp. 3d 259 (S.D.N.Y. 2019), the Government gave notice of expert testimony on “the
psychology of the pimp-prostitute relationship,” including concepts such as “trauma bonding.” Id.
at 263. The defendant interposed a Daubert challenge, arguing that the expert’s testimony was not
based on “studies or empirical data” and so could not “be assessed for reliability.” Id. (internal
8
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