Social Work Expert’s Testimony on PTSD Symptoms in Adult Women Admitted
Posted on June 10, 2025 by Expert Witness Profiler
The claims against La-Norma Ramirez and Washington County stem from Plaintiff Danyale Blackmore’s booking and release at the Washington County Jail.
Blackmore alleged that her constitutional rights were violated when she was allegedly strip-searched at the Jail.
Plaintiff designated Annette Curtis as a retained rebuttal expert. Curtis will provide testimony regarding the symptoms and diagnosis of [PTSD] in adult women.
Defendant sought to exclude or limit at trial the testimony of Plaintiff’s rebuttal expert, Curtis.
Social Work Expert Witness
Annette B. Curtis is a Licensed Clinical Social Worker (“LCSW”) with over 20 years of experience in treating women with sexual trauma and Post-Traumatic Stress Disorder.
Discussion by the Court
Curtis is Qualified to Offer Expert Testimony
The Defendant contended that Curtis was not qualified because she lacked experience working in a jail setting or with inmates.
However, the Court observed that Defendant pointed to no authority to support these propositions, and there is nothing in the record to suggest that Curtis lacked the requisite specialized knowledge, skill, experience, training, or education to testify and opine on the symptoms and diagnosis of PTSD in adult women.
Curtis’ Anticipated Testimony are Reliable and Admissible under Rule 702
Defendant argued that Curtis’ methods and opinions are unreliable because she did not examine Plaintiff, but instead relied on a review of Plaintiff’s medical records and the discovery relating to other expert witnesses in the case.
The Court held that Curtis’ report and deposition testimony demonstrated that she obtained and reviewed sufficient information to testify about and offer opinions on the symptoms and diagnosis of PTSD in adult women and the Plaintiff, as well as to critique the opinions of the Defendant’s experts. Whether obtaining more information or personally examining the Plaintiff would have been helpful to Curtis’ opinions is a matter for cross-examination.
Moreover, Curtis’ report and deposition testimony also demonstrated that she applied specific criteria and sufficient facts to form her opinions.
Specifically, provided adequate foundation and the testimony being otherwise admissible under the Federal Rules of Evidence, the Court held that Curtis may offer expert testimony and opinions regarding the symptoms and diagnosis of PTSD in adult women. Curtis may also offer expert testimony and opinions regarding circumstances that may cause sexual trauma and PTSD.
Curtis may not offer Ad Hominem opinions, or Testimony and Opinions that Invades the Exclusive Roles of the Judge and Jury
The Court held that Curtis’ speculation, ad hominem attacks on the Defendant’s expert, and personal (as opposed to expert) opinions are likewise inappropriate, irrelevant, and substantially prejudicial. In other words, Curtis’ testimony and opinions on these matters are not helpful under Rule 702.
Curtis testified in her deposition that she believed the Plaintiff suffered a traumatic event at the jail, that the Plaintiff was strip-searched in front of male deputies, and that the Plaintiff was not intoxicated. While Curtis is permitted to critique the opinions of the Defendant’s expert regarding the Plaintiff’s mental health diagnosis, the Court held that her deposition testimony should not include weighing evidence or assessing witness credibility. Basically, Curtis did not have personal knowledge of whether Plaintiff suffered a traumatic event at the jail, was strip searched in front of male deputies, or was not intoxicated.
But provided adequate foundation and the testimony being otherwise admissible under the Federal Rules of Evidence, the Court held that Curtis may rebut the opinions of Defendant’s expert regarding the medical effects of alcohol use and intoxication on an individual; how an individual’s alcohol use and intoxication affect or have implications in the proper diagnosis of medical and mental health conditions; and that if Plaintiff was not intoxicated at the time of her arrest and booking, how that affects the opinions of Defendant’s expert.
Held
The Court granted in part and denied in part the Defendant’s motion to exclude or limit at trial the testimony of Plaintiff’s expert, Annette Curtis.
Key Takeaway:
The majority of the issues the Plaintiff raised regarding the reliability of Curtis’ testimony and opinions went to weight, not reliability or admissibility. Curtis’ report and deposition testimony demonstrated that her expert testimony and opinions were the product of reliable principles and methods, which she applied reliably based on sufficient facts.
While some of the facts on which Curtis’ opinions are based are vigorously disputed by the parties, Defendant pointed to no evidence or legal authority requiring exclusion of her testimony and opinions regarding these facts. Curtis’ use of disputed facts to form her opinions regarding Plaintiff’s diagnosis did not render her testimony and opinions unreliable.
Please refer to the blogs previously published about this case:
Mental Health Expert’s PTSD Diagnosis Was Deemed Reliable
Corrections Expert’s Opinions on the Strip Search Excluded
Case Details:
| Case Caption: | Blackmore Et Al V. Carlson Et Al |
| Docket Number: | 4:21cv26 |
| Court Name: | United States District Court, Utah |
| Order Date: | June 03, 2025 |
