A New Jersey judge ruled expert testimony inadmissible for not being ‘supported by factual evidence’, but why? In this New Jersey case, Defendant Krisla Rezireksyon is accused of killing her eight year old daughter, Christiana Glenn. Ms. Rezireksyon’s defense claims she suffered from ‘diminished capacity’ and was under ‘delusional spells’ from her pastor at the time of the offense, making her incapable of knowingly and purposefully accountable for the crime.
Superior Court Judge Michael L. Ravin ruled in January that Dr. Joel Morgan, a clinical neuropsychologist, was able to testify that Ms. Rezireksyon suffered from ‘diminished capacity’ at the time of the death of her daughter. Dr. Morgan went on to diagnose Ms. Rezireksyon with ‘mild mental retardation, dependent personality disorder, psychosis, and symptoms of schizoid personality disorder’. However, Judge Ravin did not permit Dr. Morgan’s testimony that the defendant was the victim of brainwashing, or that her beliefs were ‘cult-like’ for a number of reasons:
- The claims that Ms. Rezireksyon was brainwashed and her beliefs were ‘cult-like’ were not supported by factual evidence; instead, Judge Ravin calls them ‘speculative.’ There are a number of psychological tests for doctors to follow which allow them to study, document, and diagnose mental disorders such as psychosis (which I assume Dr. Morgan provided to the court for them to be accepted). But, he failed to provide any factual evidence that she was brainwashed or had cult-like beliefs.
- The claims did not appear to be within the scope of Dr. Morgan’s expertise as a clinical neuropsychologist. Perhaps an expert in cult psychology could have provided more insight in this case.
- Dr. Morgan failed to define what a cult is and how this supported the claim that Ms. Rezireksyon was brainwashed by her pastor.
- Dr. Morgan didn’t provide support for his conclusions, except for referring to her low IQ and symptoms of depression, suggesting that she was particularly vulnerable to brainwashing.
- Dr. Morgan claimed the pastor was ‘a pathological narcissist who preys on vulnerable individuals’ but didn’t examine the pastor or any other followers of the pastor. Instead, Dr. Morgan only examined the Defendant.
‘Sufficiently reliable information’ would be well-defined, well-documented, and vetted by an expert in the proper field. Dr. Morgan will ultimately testify about Ms. Rezireksyon’s ‘diminished capacity’, but he will not be allowed to suggest she suffered from ‘cult-like’ beliefs and was brainwashed. Judge Ravin’s decision summarized it best:
“Dr. Morgan’s testimony at trial would therefore be relevant to proving that Defendant had a mental disease or defect; the question of whether or not the condition in fact constitutes a mental disease or defect is a question reserved for the jury.”