Daniels v. District of Columbia
15 F. Supp. 3d 62
| D.D.C. | 2014Background
- Daniels sues the District of Columbia and several police officers for false arrest and related damages.
- The incident occurred May 18, 2010; Daniels was hospitalized for four days after the arrest due to a high-risk pregnancy.
- The plaintiff identified four treating physicians as Medical Witnesses but did not provide Rule 26 disclosures required for expert testimony.
- Defendants moved in limine to exclude testimony and documentary evidence about Daniels’ hospitalization and causation related to the hospitalization.
- The court must decide whether treating physicians can be treated as experts under Rule 26 and whether hospitalization-related evidence is admissible, and if so, in what form.
- The court grants the motion in part and denies in part, restricting expert testimony and excluding hospitalization-related evidence to lay observations only.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether treating physicians are experts under Rule 26(a)(2) (C). | Daniels contends treating physicians can testify as fact witnesses. | Defendants contend they are experts and must disclose under Rule 26(a)(2)(C). | Treating physicians are experts under Rule 26(a)(2)(C); failure to disclose warrants exclusion. |
| Whether Medical Witnesses may testify about diagnosis and treatment. | Doctors should describe and explain diagnoses and treatments. | Such testimony constitutes expert opinion requiring proper disclosure. | Medical Witnesses may testify only as lay witnesses about non-expert observations; expert testimony is excluded. |
| Whether evidence of hospitalization is relevant and admissible as causation. | Hospitalization supports damages and distress from the incident. | Hospitalization is causally linked to preexisting pregnancy issues and risks unfair prejudice. | Evidence of hospitalization is inappropriate; excluded as irrelevant or unduly prejudicial without proper expert causation testimony. |
| Whether the IIED claim requires expert causation testimony. | IIED can be proven without expert causation. | Causation in medically complicated cases requires expert testimony. | Causation in this medically complex, pregnancy-related context requires expert testimony; lay testimony cannot prove causation. |
Key Cases Cited
- Daubert v. Merrell Dow Pharm., Inc., 509 U.S. 579 (U.S. 1993) (admissibility of expert testimony under Rule 702; reliability standard)
- Sprint/United Mgmt. Co. v. Mendelsohn, 552 U.S. 379 (U.S. 2008) (Rule 403 balancing and probative-prejudice concerns in evidentiary rulings)
- Baltimore v. B.F. Goodrich Co., 545 A.2d 1228 (D.C. 1988) (medically complicated cases require expert causation testimony)
- Daskalea v. District of Columbia, 227 F.3d 433 (D.C. Cir. 2000) (expert causation generally required in complex medical injuries)
- United States v. Ring, 706 F.3d 460 (D.C. Cir. 2013) (Rule 403/702 addressing expert evidence and prejudice)