United States v. Stahlman
United States v. John David Stahlman, 934 F.3d 1199 (2019). Decided in 11th Cir..
- COURT
- 11th Cir.
- DECIDED
- 2019
- CITATION
- 934 F.3d 1199
- OUTCOME
- Excluded
- STANDARD
- Daubert / Rule 702
- CITED BY
- 34 later opinions (CourtListener)
Exclusion of a defence expert's opinion that the defendant intended to act out a fantasy rather than to have sex with a minor was affirmed under Rule 704(b); the court declined to reach the district court's separate ruling that the opinion was unreliable under Rule 702. It separately held that the district court erred in admitting an agent's interpretation of the defendant's online communications as lay testimony after finding that the testimony involved specialised knowledge.
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READ THE OPINIONUnited States v. Stahlman, 934 F.3d 1199↗COURTLISTENER · FREE LAW PROJECT · OPENS IN THE SAME TAB
The court’s reasoning
Rule 704(b) bars an expert in a criminal case from stating an opinion about whether the defendant did or did not have the mental state constituting an element of the offence, and the proffered opinions went directly to intent. As to the agent, Rule 701(c) forbids lay opinion based on specialised knowledge within the scope of Rule 702, so an evidentiary ruling resting on the contrary view of the law was an abuse of discretion per se.
From the opinion
“Because we agree with the district court that Dr. Carr's testimony was inadmissible under Rule 704(b), we do not address its separate conclusion that his testimony was also inadmissible under Rule 702.”
Grounds argued
This ruling turned on 2 of the eight arguments that recur across the docket. Each is defined the same way on every entry, so the same ground can be followed across rulings that reached opposite results.
- Scope creep
- Whether the examiner stayed inside the technical question and out of intent, credibility, and legal conclusions. It is the most avoidable ground on this list and one of the most common.
- Fit to the issue
- Whether the opinion helps decide a fact actually in issue. Testimony can be entirely reliable and still be excluded because it answers a question the case does not ask.
Practice note
Terms used on this page
Every term below is defined in the forensic glossary — what it is, why a case turns on it, and what happens in the matter when it is mishandled.
Rulings on the same grounds
One ruling is not a rule. These are the other entries in the docket argued on the same grounds, most-cited first — including the ones that came out the other way, which are the ones worth reading before relying on this entry for anything.
ON SCOPE CREEP
- ClearOne Communications v. Biamp Systems 653 F.3d 1163 (2011) ADMITTED
- United States v. Noel 581 F.3d 490 (2009) EXCLUDED
- United States v. Hill 818 F.3d 289 (2016) ADMITTED
- Passlogix v. 2FA Technology 708 F. Supp. 2d 378 (2010) ADMITTED IN PART
ON FIT TO THE ISSUE
- Daubert v. Merrell Dow Pharmaceuticals 509 U.S. 579 (1993) ADMITTED
- Wellogix v. Accenture 716 F.3d 867 (2013) ADMITTED
- ClearOne Communications v. Biamp Systems 653 F.3d 1163 (2011) ADMITTED
- United States v. Noel 581 F.3d 490 (2009) EXCLUDED
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