Education Expert’s Testimony on School Procedures Excluded
Posted on October 28, 2025 by Expert Witness Profiler
Haverford School identified concerns with a student James’ behavior and asked his parents to withdraw him from the school mid-year. While James’ parents, the Does, acknowledged their son’s behavioral issues, they nevertheless disputed the school’s narrative of his behavior during that period. They concluded that the school asked for James’ withdrawal because he reported racial discrimination.
Haverford objected to the admission of testimony from the Does’ proffered expert, Raymond De Sabato, claiming that he lacks the requisite expertise or comprehensible methods to opine on issues in this case.
Education Expert Witness
Raymond De Sabato holds a bachelor’s degree in reading education and psychology and a master’s degree in education, with a teaching certification in reading and language arts and a focus on administration. He worked in the education field from approximately 1977-2022 as a teacher, coach, assistant principal, principal, and assistant head of school at private schools at the middle-and-high-school levels.
Discussion by the Court
In his report, De Sabato concluded that Haverford breached its duty and the professional standard of care with respect to James by failing to (1) “reasonably investigate and address the allegations of racial harassment and discrimination of James” and (2) “acting unreasonably in the manner in which it disciplined James by removing him from the School in the middle of the third grade year.”
According to Haverford, De Sabato’s purported expertise is based solely upon his career as an educator, rather than any specialized training or education.
Plaintiffs opposed Haverford’s motion, highlighting De Sabato’s discussion of best practices for dealing with struggling students, from the perspective of the private school experience.
Analysis
Despite De Sabato’s expertise as a teacher and administrator at private schools for 50 years, the Court held that De Sabato did not articulate a reliable method through which he reached his opinions in this case.
He described his expert methodology as “including the gathering, review, and analysis of all available and relevant documents, evidence, information, and testimony” based upon his “education, training, and professional experience in the field of education administration.” De Sabato further explained that his analysis focused on Haverford’s maintenance and implementation of racial harassment and abuse procedures, its investigation into such alleged harassment, and its disciplinary process for James.
This is not a methodology in the Rule 702 sense, but is rather a description of how thinking works: collect and assess the relevant information and use experience to reach a conclusion. The Court did not find any indication of how the jury will be able to follow along with that thought process if challenged – a critical safeguard of Rule 702.
Held
The Court granted the Defendants’ motion to exclude the testimony of Raymond De Sabato.
Key Takeaway:
Sabato spoke in broad strokes about his focus on school procedures for racial harassment and abuse and investigations into such allegations, without providing any details as to what an effective or ineffective system looks like. Nor did he offer any insight into what an appropriate disciplinary process would be for a student exhibiting James’ behaviors.
It is simply not enough to say, “I reviewed the relevant documents, based upon my experience in this space, and reached my conclusions by focusing on the things I was asked to assess.”
Case Details:
| Case Caption: | Doe V. Haverford School |
| Docket Number: | 2:24cv618 |
| Court Name: | United States District Court, Pennsylvania Eastern |
| Order Date: | October 27, 2025 |
