Law Enforcement Expert’s Testimony on Tunnel Vision Excluded
Posted on January 19, 2026 by Expert Witness Profiler
Eric Kelley contended that he was wrongfully incarcerated for a 1993 murder and robbery for 24 years until DNA testing provided a basis for the trial court to vacate his convictions, and the State declined to retry him, Kelley then sued several members of the Paterson Police Department (“PPD”) who allegedly violated his constitutional rights and the City of Paterson (“Paterson”).
To testify at trial, Paterson retained Ronald Hampton, a twenty-five-year veteran of the New Jersey State Police, as an expert witness on the policies and procedures of the PPD during the relevant time. Plaintiff, however, filed a motion to exclude the testimony of Defendant’s expert, Hampton.
Law Enforcement Expert Witness
Ronald Hampton, M.A., CFE served for twenty-five (25) years with the New Jersey State Police in various assignments and capacities before retiring on September 1, 2019.
He graduated from Fairleigh Dickinson University, Rutherford, New Jersey, with a Bachelor’s Degree in Political Science in 1992 and Rutgers University, Newark, New Jersey, with a Master’s Degree in Criminal Justice in 2003. Hampton also attended and graduated from American Military University with a Master’s Degree in Management in 2014. He is a graduate of the 241st session of the FBI National Academy (2010). He is also a Certified Fraud Examiner (CFE), having received certification in 2018.
Discussion by the Court
The parties dispute Hampton’s social psychology qualifications, the reliability of Hampton’s methodology, and the fit between his proffered testimony and the issues in this case.
1. Rebuttal Report
The Court excluded Hampton’s entire proffered rebuttal testimony because his rebuttal report intrudes on the province of the jury by making credibility determinations, opining on legal issues, and regurgitating fact witness testimony.
First, Hampton inappropriately commented on witnesses’ knowledge or understanding. Second, Hampton improperly opined about legal requirements. Lastly, Hampton unacceptably weighed conflicting evidence and witnesses’ credibility.
Additionally, Hampton threatened to waste trial time by regurgitating deposition testimony with minimal to no analysis. Basically, Hampton’s summaries of witness testimony “are matters that would be within the common understanding of regular citizens and do not require—and are not benefited by—the opinions of a police practices expert.”
Finally, Hampton is not a social psychologist, yet he discusses psychological concepts such as tunnel vision, contamination, and psychological factors relating to Kelley’s confession.
In sum, the Court excluded Hampton’s rebuttal report for invading the jury’s province, and for offering new opinions improperly raised on rebuttal.
2. Opening Report
To begin with, Hampton’s opening report generally marched through the background of the PPD’s policies and procedures in effect in 1993, how those policies compared to those in place at other law enforcement agencies, and how they evolved over time.
Although Plaintiff conceded that such testimony could assist “in determining whether the [police] practices differed from standard law enforcement practices,” the Court nonetheless had to address Plaintiff’s objections to Hampton’s methodology.
Hampton’s “application of extensive experience to analyze” the PPD’s policies and procedures is a reliable methodology based on his 25 years with the New Jersey State Police.
Nevertheless, the Court excluded several lines of testimony within the opening report. First, Hampton may not testify about irrelevant matters, such as, inter alia, the rules governing officer appearance. Second, Hampton may not reference the testimony of fact witnesses in this case, as he does with Lieutenant Spagnola and Chief Munsey. Third, Hampton may not speculate. Finally, Hampton may not utilize materials prepared after 1993 to support opinions regarding policies or procedures in place in 1993.
Held
The Court granted in part and denied in part the Plaintiff Eric Kelley’s motion in limine to exclude the testimony Defendants’ expert Ronald Hampton.
Key Takeaway
Police experts regularly testify about non-scientific topics based on their own training and experience. Hampton made several assertions about the PPD’s policies and procedures, which he attempted to prove based on his own extensive training and experience.
Case Details:
| Case Caption: | Kelley V. Reyes |
| Docket Number: | 2:19cv17911 |
| Court Name: | United States District Court, New Jersey |
| Order Date: | January 14, 2026 |
