Kelley v. Reyes

Summary

The United States District Court for the District of New Jersey ruled on portions of the parties’ motions in limine before trial in Eric Kelley’s wrongful-conviction civil rights action. The court granted in part and denied in part Kelley’s Daubert motion, excluding the defense expert’s rebuttal testimony and limiting portions of his opening testimony. The court denied in part the City of Paterson’s motion concerning newspaper articles, while reserving judgment on hearsay within the articles and Rule 403 issues.

Holdings

1. Hampton's proposed rebuttal testimony was inadmissible in full because it failed Daubert's fit requirement and Hampton was not qualified as a social psychologist to rebut Plaintiff's social-psychology expert. The testimony also improperly addressed witness knowledge, legal requirements, credibility, and factual narratives.
2. Hampton could testify, based on his training and experience, about how Paterson's police practices compared with other departments at the relevant time and how those practices evolved. He could not testify about irrelevant matters, fact-witness testimony, speculation, or 1993 policies based on materials created after 1993.
3. The Court denied Paterson's motion in limine insofar as it challenged the newspaper articles as hearsay because the articles were prepared before January 1, 1998 and therefore fell within the ancient-documents exception, subject to unresolved issues involving hearsay within the articles.
4. The newspaper articles were self-authenticating under Federal Rule of Evidence 902(6), and, independently, Plaintiff made the showing required to authenticate them as ancient documents under Rule 901(b)(8).

Questions Presented

1. Whether Ronald Hampton's rebuttal and opening expert testimony satisfied Federal Rule of Evidence 702 and Daubert.
2. Whether Hampton's proposed testimony improperly invaded the jury's province, offered legal conclusions, assessed witness credibility, relied on speculation, or relied on later-created materials to address 1993 practices.
3. Whether the newspaper articles were inadmissible hearsay or insufficiently authenticated.
4. Whether remaining hearsay-within-hearsay and Rule 403 objections to the newspaper articles should be resolved before trial.

Disposition

other