U.S. v. Truitt

Dist. Ct. did not err in excluding plaintiff’s proposed witness in prosecution on charges of making false statements against U.S. and theft of govt. funds arising out of defendant’s filing of patently false tax returns, where plaintiff sought expert to establish that she did not have sufficient mens rea because she truly believed that her series of tax returns seeking $300,000 refunds based on non-existent trusts were legitimate. Dist. Ct. could properly find that expert lacked relevant expertise to support claim that defendant’s conduct was traceable to her membership in “charismatic group,” where: (1) expert lacked expertise needed to speak authoritatively about charismatic groups, since expert had worked on only single case involving religious themes of any kind; (2) expert’s methods were unreliable and inconsistent with methods used by expert who plaintiff’s expert relied upon to learn about said groups; and (3) expert’s definition of charismatic group was based only on plaintiff’s own self-interest statements as opposed to interviews of others in said group.