Psychology Expert’s Opinion on the Harm Resulting from the Alleged Misconduct Admitted
Posted on August 29, 2025 by Expert Witness Profiler
This is a pro se prisoner action brought by Plaintiff William A. White relating to White’s detention at the John E. Polk Correctional Facility, in Sanford, Florida, between May and December 2014. Plaintiff’s claims arise out of his placement in the isolation unit due to information received from the U.S. Marshals that White was a neo-Nazi with white supremacist views creating safety and security concerns.
Dr. Richard M. Samuels has provided a forty-page report (including appendices) titled Independent Psychological Evaluation, opining as to the effects of Defendants’ alleged misconduct on Plaintiff’s psychological health.
Defendants filed a Daubert motion to exclude opinions offered by Plaintiff’s psychological expert, Samuels.
Psychology Expert Witness
Dr. Richard M. Samuels has conducted 2300 psychological evaluations till date. He is licensed in Arizona and New Jersey and is a Member of the Arizona Supreme Court Competent Professional Mental Health Provider Panel, Maricopa County. He has been court-appointed in most Arizona, New York, and New Jersey counties.
Discussion by the Court
Basically, Defendants contended that Samuels’ report “contains certain opinions of a medical nature [that Samuels] does not appear qualified to offer” and that Samuels provided “certain inflammatory opinions about historical references to interrogation techniques,” which are irrelevant. Defendants further maintained that the opinions offered by Samuels are unreliable because they are based on only a portion of the evidence and on Plaintiff’s self-serving statements.
Additionally, Defendants argued that the report is not sworn or verified and is inadmissible hearsay, and they noted that other courts have questioned the opinions of Samuels.
Analysis
Given his extensive credentials in the field of psychology, the Court held that Samuels is qualified to testify as an expert regarding his psychological evaluation of Plaintiff. Moreover, Samuels persuasively outlined his methodology in the report, and any alleged flaws in the methodology can be addressed through cross-examination.
The opinions offered by Samuels are also likely to assist the factfinder because they provide psychological insights into how Defendants’ alleged misconduct could have harmed Plaintiff.
Plaintiff represented to the Court that Samuels will not testify to matters outside his report or to “the legal standards of ‘physical injury’ or ‘greater than de minimis‘” harm. Additionally, the Court noted that Samuels may not present any legal conclusions at trial.
Held
The Court denied the Defendants’ Daubert motion to exclude the testimony of Richard Samuels.
Key Takeaway:
Because Samuels is not merely transmitting hearsay, is qualified to provide psychological opinions, has used a sufficiently reliable methodology, and is likely to assist the factfinder as to Plaintiff’s purported damages, the Court held that his opinions are not due to be excluded under Daubert.
Case Details:
| Case Caption: | White V. Eslinger Et Al |
| Docket Number: | 6:14cv936 |
| Court Name: | United States District Court, Florida Middle |
| Order Date: | August 27, 2025 |
