Summary
This Delaware Superior Court order denies the defendant's pro se motion in limine to exclude expert testimony from Dr. Stephen Mechanick regarding the defendant's competency at the time he entered a guilty plea. The court held that the defendant waived any challenge to the admissibility or qualifications of the expert by failing to object before or during the December 2024 competency hearing, as required by Delaware Rule of Evidence 702 and Daubert standards. Consequently, the motion to exclude the testimony was procedurally barred and denied.
Topics
Practice areas
Questions Presented
- Whether Defendant's untimely motion in limine to exclude Dr. Mechanick's expert testimony is barred by Delaware Rule of Evidence 103 and Daubert timing requirements.
Holdings
- The motion is denied because Defendant waived any Daubert‑based challenge by failing to timely object to the expert testimony.
Key quotations
“Because Defendant failed to timely object, any challenge to Dr. Mechanick’s qualifications or opinions has been waived.”
Factual background
Defendant George Curtis entered a guilty plea in 2023, later claiming he was not mentally competent due to PTSD, bipolar II, dissociative identity disorder, and anxiety. He was evaluated by Dr. Laura Cooney‑Koss and Dr. Stephen Mechanick, whose competency report was provided to the State. Dr. Mechanick testified at a competency hearing in December 2024.
Procedural history
Defendant filed a motion to withdraw his guilty plea and was evaluated by two psychologists. The court heard expert testimony on his competency in December 2024, admitting the testimony. In July 2025 the Defendant filed a pro se motion in limine to exclude that testimony, which the State opposed. The court denied the motion.