Court – United States District Court for the District of Columbia Jurisdiction – Federal Daubert Factor Involved – Qualification Case Stage – Trial Ruling Type – Daubert Case Name – Sacchetti v. Gallaudet University Citation – 2018 U.S. Dist. LEXIS 184533
This case arose when Gianni Manganelli, a deaf student at Gallaudet University, committed suicide on March 30, 2014, in Silver Spring, Maryland. Manganelli was a scholarship student who suffered from seizures and mental illness. His mother, Terrylene Sacchetti, had informed the university about her son’s mental illness and was assured that the university staff would provide her son with the proper care.
Beginning in August of 2013, Manganelli’s behavior began declining. The university staff suspected a mental health issue but did not inform Manganelli’s parents about his behavioral changes. In Manganelli’s initial screening at the Gallaudet mental health center, it was noted that he “was agitated, confrontational, defensive and guarded,” as well as anxious and depressed. Sacchetti had requested that Gallaudet’s mental health center notify her of any depressive episodes her son experienced so she could take him to a hospital for proper care.
Manganelli also had an issue with his roommate, who accused him of being nosy and looking through his possessions. Manganelli was later arrested by the Gallaudet Police. Neither Gallaudet’s mental health center nor his parents were informed about his mental condition following this incident.
Before committing suicide, Manganelli had requested that his mother to pick him up from his dormitory. When she came to pick him up, she could sense that he was not well. When they arrived home, Manganelli refused to enter the apartment and expressed that he wanted to return to Gallaudet. Manganelli then suddenly left the apartment. The next morning he came back but ran away again as his mother was preparing to take him to the hospital. Manganelli was later found dead near the apartment.
The plaintiffs, Terrylene Sacchetti and Robert Manganelli, brought this suit against defendants Gallaudet University and the District of Columbia. They asserted violations of the Americans with Disabilities Act (ADA) and common law claims for wrongful death, survival, negligent infliction of emotional distress, and false arrest.
The Court dismissed the plaintiffs’ wrongful death, negligence, survival, negligent infliction of emotional distress, and ADA claims and also denied Gallaudet’s motion to dismiss the false arrest claim asserted against the university.
Following the close of discovery, the defendants filed their motions for summary judgment as well as a motion to exclude the testimony of Dr. Michael Welner, M.D., the forensic psychiatrist designated by the plaintiffs. The plaintiffs also filed their motion to strike two exhibits attached to the District of Columbia’s motion for summary judgment.
Skepticism Surrounding the Plaintiffs’ Forensic Psychiatry Expert Witness
The plaintiffs had offered Dr. Welner’s testimony “to establish the causal connection between the false arrest, it’s consequences, and the plaintiffs’ injuries and damages.”
Dr. Welner stated that, based on his professional opinion and with a reasonable degree of psychiatric certainty, the arrest and its consequences led to Manganelli’s decision to commit suicide. He further opined that the arrest and the events that followed caused Manganelli to become hopeless, and this hopelessness has a direct relationship with the suicide. Dr.Welner also stated that Manganelli committed suicide within hours of his eviction from college, which indicated that it was not pre-planned and was indeed the result of his arrest.
The defendants argued that Dr. Welner’s opinions should be excluded because they failed to meet the threshold requirements of reliability and relevance under Rule 702 of the Federal Rule of Evidence. They also argued that Dr. Welner’s opinions were irrelevant because they offered no factual support for his conclusions, nor any foundation in scientific evaluation or analysis. The defendants claimed that Dr. Welner’s testimony could not relate to the applicable legal standard for causation because it never referred to a treatise, manual, study, or any other source of scientific data that might support his conclusions regarding Manganelli’s alleged hopelessness.
Held
The Court could not arrive at the conclusion that Dr. Welner’s testimony was the product of reliable principles and methods. The Court noted that even if they assumed that a “psychological autopsy” would be a reliable method for assessing causation in this case, Dr. Welner did not purport to have employed this method.
In discussing “psychological autopsy”, the Court relied on “In re Neurontin Marketing, Sales Practices, and Products Liability Litigation”, where the United States District Court for the District of Massachusetts had described a psychological autopsy as “a standardized, systematic checklist which could be used to assemble and organize information so that a qualified suicidologist or other appropriate health care professional would have the information necessary to consider all of the various risk factors which may or may not have contributed in a material way to any person’s suicide.”
In this case, Dr. Welner had not purported to use any specific tools or methods to guide his analysis. When asked, Dr. Welner could not explain what a forensic psychiatric assessment typically involved or how he had conducted his assessment in this case. The Court also noted that Dr. Welner testified that “forensic psychiatry” is a catchall term for “working within legal matters where there’s a specific context to the clinical question” but failed to support this claim with any relevant sources. It was determined that the expert had relied solely on his experience in arriving at his conclusions regarding Manganelli’s hopelessness. The Court could not conclude that the requirements of Rule 702 and Daubert had been satisfied and the motion to exclude Dr. Welner’s testimony was granted.
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