Valentine v. Torres-Quezada

Background

Javontae Valentine filed a claim under 42 U.S.C. § 1983 against five Salinas Valley State Prison correctional officers: A. Torres-Quezada, N. Reveles, M. Reyes-Diaz, A. Cervantez, and A. Camacho. He alleges that each officer used excessive force against him in violation of the Eighth Amendment. The dispute arises from an August 12, 2021 incident that included a nasal fracture requiring surgery. The order states that the facts of the incident and whether the force was excessive are disputed.

The parties filed motions under Federal Rule of Evidence 702 and the standard established in Daubert v. Merrell Dow Pharmaceuticals, Inc. The court explained that it acts as a gatekeeper for expert testimony, deciding whether proposed testimony rests on a reliable foundation and is relevant and helpful to the jury, rather than deciding whether the expert is ultimately correct.

Use-of-Force Experts

The court denied Valentine’s motion to exclude Scott DeFoe as an expert. DeFoe may testify about his knowledge of best practices, California Department of Corrections and Rehabilitation regulations, and use-of-force techniques. He may apply his experience to particular hypotheticals using assumed facts, subject to the order’s trial guidelines. The court excluded any testimony about an officer who was not present during the incident because it would not assist the jury, but concluded that this issue did not make DeFoe’s opinions wholly unreliable. The court treated Valentine’s other objections as challenges to the weight of DeFoe’s testimony rather than its admissibility.

The court granted in part and denied in part the defendants’ motion to exclude Williams Adams. Adams may testify, within the stated limits, about best practices, correctional regulations, and use-of-force techniques, including applying his experience to hypotheticals using assumed facts. The court excluded Adams’s testimony about “prison politics” because it would not assist the jury in deciding whether the defendants used excessive force. The order also states that neither DeFoe nor Adams may testify that the force used in this case was reasonable, excessive, or unnecessary. Objections to legal terminology were left for contemporaneous objections at trial.

Medical Experts

The court denied Valentine’s motion to exclude Dr. Dave Miles Atkin. Valentine argued that Dr. Atkin’s opinions about Valentine’s facial, nasal, and head fractures and subsequent septoplasty were outside the scope of Dr. Atkin’s expertise as an orthopedist specializing in sports medicine. The court concluded that this issue went to the weight of the testimony, which Valentine could challenge through cross-examination, rather than its admissibility. The court also rejected the arguments that Dr. Atkin’s methodology was flawed or that his opinion about Valentine and Torres-Quezada engaging in hand-to-hand combat required wholesale exclusion.

The order discusses defendants’ objections concerning Dr. William Weber’s opinions about the long-term effects of Valentine’s injuries, psychiatric symptoms, and whether kicks caused Valentine’s facial injuries. The excerpt identifies the court’s discussion of these objections but does not clearly state a separate final disposition for each Weber objection. The order’s overall conclusion states that the parties’ Daubert motions were granted in part and denied in part.

Trial Guidelines and Disposition

The court ruled that expert reports will not be admitted as exhibits. Experts may not cite or recite the evidentiary record during their testimony. The parties may seek clarification about the permitted scope of testimony at the pretrial conference, and they may not use excluded testimony without first asking to be heard if they believe another party has opened the door.

Judge Jeffrey White concluded: “For the foregoing reasons, the Court GRANTS, IN PART, AND DENIES, IN PART, the parties’ Daubert motions.” The order addressed the admissibility and limits of expert testimony; it did not resolve the underlying excessive-force claim.