---
title: "Law Enforcement Expert Not Allowed to Opine on Training And Supervision"
meta:
  "og:description": "The law enforcement expert was not allowed to testify about the purported failure of the city to train or supervise the canine handlers"
  "og:title": "Law Enforcement Expert Not Allowed to Opine on Training And Supervision"
  author: "Expert Witness Profiler"
  description: "The law enforcement expert was not allowed to testify about the purported failure of the city to train or supervise the canine handlers"
---

# Law Enforcement Expert Not Allowed to Opine on Training And Supervision

Posted on June 10, 2026 by Expert Witness Profiler

Plaintiff Fernando Villanueva-Galvez claimed that Officer Eliseo Anaya’s use of a police canine to locate and arrest him constituted excessive force in violation of the Fourth Amendment.

Villanueva-Galvez proposed to present [Ernest Burwell](https://expertwitnessprofiler.com/expert-witness/Ernest-Burwell/1543778)‘s testimony regarding police canine practices. Defendants did not challenge Burwell’s qualifications. Nor did the Defendants seek to preclude Burwell from testifying entirely. Rather, Defendants argued that Burwell should not be permitted to testify about legal conclusions regarding the severity and reasonableness about the use of force in this case, how disputed factual issues should be resolved by the jury, police canine practices for which he cites no reliable data or other support, and purported deficiencies in the City’s canine training and supervision practices for which he cites no relevant professional standards or reliable principles.