Two Stories: The Harry Potter Edition

VOLDEMORT IN COURT

It was 1995 when the good people of the Land of Enchantment (New Mexico for you folks who haven't marveled at the Sangre de Cristo mountains), through their elected representatives in the state Senate, unanimously approved an amendment to a bit of legislation.

When a psychologist or psychiatrist testifies during a defendant's competency hearing, the psychologist or psychiatrist shall wear a cone-shaped hat that is not less than two feet tall. The surface of the hat shall be imprinted with stars and lightning bolts.

Additionally, a psychologist or psychiatrist shall be required to don a white beard that is not less than 18 inches in length, and shall punctuate crucial elements of his testimony by stabbing the air with a wand. Whenever a psychologist or psychiatrist provides expert testimony regarding a defendant's competency, the bailiff shall contemporaneously dim the courtroom lights and administer two strikes to a Chinese gong.

Did I mention that it passed unanimously?

It's not just the mental health folks, of course. So-called "experts" who testify in court are, too often, no more than paid whores.  Not all, maybe not even most.  But plenty.  And of course juries struggle because they really haven't a clue whether Expert A for the prosecution who says "Yea" has any better handle on the truth or any greater degree of integrity than Expert B for the defense who says "Nay."  Who's more credible has, frankly, almost nothing to do with who's right.

Enter Dr. William B. Barr, "Witness for the Prosecution," as the headline of Russ Buettner's article in the Times puts it.

After hours of harsh questioning from a defense lawyer, the psychologist testifying for prosecutors twisted ever so slightly in the witness stand.

How could it be, the defense lawyer had asked, that 20 other doctors examined the defendant, a Portuguese fashion model, and concluded he was in the throes of a manic episode at the time he killed his companion — and only you determined that he was faking it?

How could it be that the rule book for your profession says a manic episode can come on rapidly — and yet you insist that the book is wrong on that point?

And how could you conclude that the defendant, who has a degree in physical education from a college in Portugal, learned how to invent an insanity defense in a college psychology class, without having any idea whether he even took such a class?

With that, William B. Barr shifted a bit in the witness chair. He tilted his head to one side, but he did not lose his cool.

“It’s my assumption that getting a general degree from a university, that chances are that someone has studied psychology,” he answered calmly.

Barr has respectable credentials.  He also has a point of view.  That's one reason the prosecutors turn to him.  The other is that he presents well.  Jurors believe him.  They believed him in that case, and the defendant's now serving time for murder.  

It's theoretically possible, I suppose, that Barr was right in that case.  The thing is that the jurors didn't know either.  But they believed - or believed enough.  After all, proof in the courtroom and the law isn't about what happened.  It isn't about what's true or correct.  Proof, including proof beyond a reasonable doubt, is simply whatever the jury believes.  (It's a bonus, of course, if what the jury believes comports with reality, but it's not a feature of the system.)

DUMBLEDORE KEPT OUT OF COURT

Occasionally, the experts agree.  They do about Warren Lee Hill.  All seven of them.  The ones tapped by the state of Georgia and the ones Hill's lawyers hired.  They all agree.  He has mental retardation.  

That might not be a big deal, but Hill's on death row and Georgia wants to kill him.  The thing is, unless those experts are all wrong, it's unconstitutional to execute him.  (See Atkins v. Virginia.)  And there's no evidence that they're all wrong.  Georgia's efforts have so far been stymied, but , of course, is planning to kill him.  They've been stymied in the effort so far, but it looks like, well really, it may all be up to Anthony Kennedy.

See, Georgia said that Hill didn't prove beyond a reasonable doubt that he drooled uncontrollably and walked hunched over and couldn't tie his shoelaces had mental retardation which is the peculiar and perhaps unconstitutional test (I say "perhaps" because the question hasn't been answered by the courts) that the Peach Tree State employs.  And Hill has already had one pass through federal court which means he can't go back there.  So he's now gone directly to SCOTUS.  Jesse Wegman in the Times.

The Supreme Court’s next term is full of big-ticket issues — from campaign finance to affirmative action to the separation of powers — but a largely overlooked death-penalty appeal the court hasn’t agreed to hear yet could clarify how broadly it views its ultimate power to stop unjust executions.

Of course, talking about the Court as if it's a unified body with a single point of view is to miss the point rather dramatically.  The question isn't how the Court "views its ultimate power," it's how 5 votes come out.  Typically in these cases (not always, but typically) that means, as I said, that Anthony Kennedy probably holds Warren Lee Hill's life in his hands.

My guess is that he doesn't see it exactly that way.  I suspect he thinks of himself as a judge/Justice making a decision.  Which he is, of course.  But he's also in this case (if the vote turns 5-4, as it very well could) a god with the very specific power of life or death over an individual guy.  

Whichever side you're on, there's something troubling about a system that relies on the wisdom and judgment of any one person to decide whether this person or that one should be killed.

There are, of course, two solutions.  Stop killing people or make the decisions of the jury unreviewable.  The latter guarantees that legal and factual outrages will never be checked.  The former just means we don't go out of our way to make corpses and to turn prison guards into killers.  

Seems like an easy choice to me.  But it's not where we are.  

Which, again, puts it on Anthony Kennedy.

None Dare Call It Bullshit

But my guy's gonna say it ain't so.  That's reasonable doubt, so I can't be guilty.  Ain't taking no deal.

We've all heard that from our clients.  And then we've watched them hauled off to the pokey because, well, as I've said repeatedly, trials are about proof and proof is whatever the jury believes.  And the jury tends to believe the cops and the alleged victims rather than, say, the defendant's mother or best friend.
But there is this thing about reasonable doubt.  Not just any old doubt.  Reasonable doubt.  And the proof is supposed to be beyond it.
I've been reading (slogging, might be a better word) through the transcript of a capital trial, but really, it could be any trial, civil or criminal.  There are expert witnesses on both sides.  Each is highly credentialed.  And each is determined by the court to be an expert in the same field.*
Each looks at the same evidence.  Defense expert says A.  State expert looks at the same stuff and says not A.
The jury goes back to deliberate.
Guilty or not guilty?
The outcome rests on whether it's A or not A.
The jury has been told it can believe all, some, or none of what any witness has to say.  But it cannot find the defendant guilty unless the state proves guilt beyond a reasonable doubt.  That is, the jury must be convinced, beyond a reasonable doubt, that the state's witness expert is right, that not A.
Here are the three possibilities:

1. One expert is incompetent.
2. One expert is a liar.
3. Experts disagree.

Let's consider those in turn.  
Incompetence
Both experts have credentials, as they say, up the wazoo.  Degrees, affiliations, experience.  Neither side disputed the expertise of the witness on the other side.  And the judge, the authority in the courtroom made specific findings, aloud and on the record in front of the jurors, that each is in fact an expert.
Have the jurors any basis on which to believe one incompetent?
No.  A juror who thought one or the other expert incompetent wouldn't be following her oath.
Lies
Sure, could be.  Witnesses lie under oath all the time.
Cops do it so much there's even a term for it.  It's called testilying.
Now, there are experts and experts.  Some really are whores who'll say whatever they're paid to say.  But there aren't many of them and they don't last long because, frankly, it's obvious.  They're charlatans and mountebanks and everyone can see it.  Competent lawyers don't use them because they won't help.
And serious experts, they don't want to damage their reputation by selling it to the highest bidder.
Disagreement
These two guy looked at the same stuff and just interpreted it differently.  They have specialized training the jury doesn't have.  Education, affiliations, experience.  One says it's flu the other says pneumonia.  One says the widget was badly manufactured, and here's why.  The other says the widget was just fine until the frazmut smashed into it, and here's how I can tell.
Maybe that mushroom is poisonous.  Maybe not.
Maybe global warming.  Then again, maybe it's just getting hotter.

Anecdote

Some years ago, I sat on a jury in a civil case.  The issue, the only issue, was whether the fact that the plaintiff was in more pain after the accident than before was a function of the accident or a coincidentally timed consequence of an earlier injury. 

There were opposing experts.  One we concluded was a whore.  The other admitted cheating the defendant.  One might have been right.  I suppose one has to have been right, in the same way that a stopped clock is right twice a day.  I mean, their positions were X and not X.  So sure, however dishonestly they came to their conclusions, one was right.  It's just that there was no way to tell which one.

Except, she was in more pain after the accident than before.  With no reason to believe the expert who said coincidence, the likelihood was that the accident caused the pain.  Accidents, after all, will do that.

Here's the thing, though.  Civil cases are decided by a preponderance of the evidence.  More probable than not.  She didn't have to prove beyond a reasonable doubt that the accident did it.  If she'd had to prove that, we'd have voted against her. 

End of Anecdote

OK, here's the point.

We look to experts because jurors aren't competent to answer the question.  Is it cancer or a calcium deposit?  Damned if I know.  The jurors really can't tell, either.

Yet they have the job of deciding whether it's proved beyond a reasonable doubt.  When the oncologists disagree.

In an honest system, we'd acknowledge that the state simply hasn't proved it unless one of the experts is believed, beyond a reasonable doubt, to be flat out lying.

Not wrong.

Crooked.

And we'd ask the jury to make a special finding.  If they didn't say 

Fucking asshole lying sack of shit,

then it would have to be Not guilty.  No matter what they decided.

Our legal system doesn't live in that world.  We ask jurors to decide whether the skull fracture was caused by a bat or an auto accident, whether the accused has mental retardation, whether the guy will be dangerous in the future, whether the baby was dropped or thrown. Whether the DNA was his or not.

And, and here's the bottom line.

They can't.  

And yet we send men to death row because of what they say.

In their ignorance.

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*For any non-lawyers reading this, that's a standard thing.  The lawyers put forth the purported expert's credentials in order to show that the person is, in fact, an expert and asks the judge to make that finding which allows the witness to offer opinions within her field of expertise.

Take Me to Your Fjord

Oh to be in Norway now that winter's nigh!

Well, maybe not.*  Nothing against Norway which has many fjords to recommend it and which I'd actually like to visit someday, but there is much to keep me occupied here.  Still, anywhere that can yield this headline to an AP story in the Gray Lady is worth attention.

Norway: Killer of 77 Was Insane During Rampage, Prosecution Says

I mean, really?  The prosecution says he was insane?  The prosecution? The fucking prosecution says he was nuts?

Here it's a full scale battle.  Consider Anthony Sowell, convicted killer of 11.  He kept the bodies in and around his home for years.  His lawyer, John Parker, explained to the jury that

[A]nyone who lives in a house for two years with the rotting remains of his murder victims must have a mental problem.

Which seems kinda self-evident to me, though the prosecutor disputed it.  As I said in full snark, quoting the AP report on the jury argument,

Assistant prosecutor Pinkey Carr said Sowell deserves to die for his crimes and responded to the comments about his mental condition by saying: “He’s crazy like a fox. He’s evil.”

See, it was all carefully done so that someday when he was prosecuted for the killings he could argue that he must have been insane.  But, nah.  Criminal mastermind.

Which is, of course, bullshit.

But it's the prosecutorial mindset.  And, oh, yeah, it's also our law.

Here's the Ohio statute on being not guilty by reason of insanity (which we call NGRI for simplicity).**

A person is “not guilty by reason of insanity” relative to a charge of an offense only if the person proves, in the manner specified in section 2901.05 of the Revised Code, that at the time of the commission of the offense, the person did not know, as a result of a severe mental disease or defect, the wrongfulness of the person’s acts.

Of course, that's not the same as just being crazy as a bedbug.  And actually Parker was arguing to the jury that they ought to spare Sowell's life, not find him NGRI, so the standard isn't perfect but you get the point.  Sowell was clearly nuts.  Just not legally nuts so as to be locked up in what used to be called an insane asylum for the rest of his life instead of locked up in prison until the state gets around to murdering him.

But back to Norway for a minute where the standards make some sense and where the prosecutor actually said they applied.  Here's the test as I understand it from the media (and I'm summarizing, not quoting).

Was the person psychotic at the time of the offense? That is, was he acting under gross delusions about reality so that he didn't ?

Now, that's something less than, say, he thought he was playing ping pong but was in fact raping and pillaging.  But if you're talking about criminal responsibility it makes some sense.  If a person is so out-of-touch with reality that he has no grasp of the world, how can we say he's fully responsible for his acts?  Well, we can in this country because we do.  (Or is it that we do because we can?) But not in Norway.

Naturally, we're horrified by the Norwegian approach.  Debra Saunders in the San Francisco (yes, that San Francisco) Chronicle.

So why do I think Oslo's chosen experts have decided that Breivik was insane? They're so sublime, they don't know how to recognize evil.

Of course, another reason might be because the experts spent a whole shitload of time examining him and concluded that he was psychotic and delusional which is the Norway standard.  Here's the AP story in the Times again.

The court-ordered assessment by two psychiatrists found that Mr. Breivik, 32, an anti-Muslim militant, was psychotic during the attacks. It will be reviewed by a forensic panel before the Oslo district court rules on his mental state. 
The conclusions contrasted with earlier comments by the head of the review panel, who said in late July that it was unlikely that Mr. Breivik would be declared insane because the attacks were so carefully planned and executed. But prosecutors insisted that the psychiatric report described a man living in a “delusional universe,” a paranoid schizophrenic who had lost touch with reality.

But then we don't care about that.  (See my earlier post on the Norwegian horror in which I explored Professor Thane Rosenbaum's lament that our criminal justice system doesn't channel Nancy Grace on guilt and punishment.)

Which brings me to the second point (or is the third).

Scott Greenfield this morning wrote about Fordham Law professor John Pfaff's post over at prawfsblawg discussing the ability of juries to deal with conflicting scientific evidence.  Here's the short version of the problem, and in fact it applies to everything that passes for expert testimony.

The bedrock assumption of our jury system (criminal, but civil too, by the way) is that the collective wisdom of 12 ordinary folk can tell when a witness is lying (or reporting on misperception) and when one is telling the truth based on watching and listening to the witness testify on direct and then on cross-examination. Whether or not that's true, direct testimony and cross examination will not help jurors accurately figure out whether computer models that show global warming will end civilization as we know it within 100 years are more accurate than computer models that show it will have no substantial effect.

That is, expert testimony is so different in kind from other testimony that when experts disagree, juries can only guess.  Hell, if the scientists can't agree about global warming, how can we expect the jurors figure it out.

Which means, really, that if the experts disagree on an element of the offense, it clearly can't really have been proved beyond a reasonable doubt since that would mean the other (court-certified) expert was offering an unreasonable (and therefore improperly admitted) opinion.

And of course that means that our system is wholly fucked, which you knew anyway (or knew I thought so, at least, if you've been reading this blawg for a while - and if so, how come you didn't convince the ABA to make me a finalist in the blawgoff?  But I digress).

It's a simple point, made more complicated by Pfaff's  effort at quantification and invocation of Rumsfeld Koan.***

Of course, juries are already free to find a “known unknown” if they wish. I want to push the issue further: as a matter of law, should we compel such a non-finding? Even before getting to questions of jury competence, is there some sort of particularly important meta-evidence we get from credible dueling experts? Does the very inability to agree suggest, at least in criminal cases, that as a matter of law there is no fact for the jury to find? We know that we don’t know, and it is unreasonable to argue that you do know in such a setting.

Even if you’re not convinced by this argument—and I’m still trying to decide if I am—the jurors’ lack of epistemic competence may still play a role: while perhaps in theory there is some fact to be “found” here, the people we are asking to find it are effectively blind. Jury pools are not well-educated: at best about half are college graduates (and this from a study set in Connecticut, the sixth-best educated state in the country), and few college graduates have real math/science training. So if dueling experts do not theoretically demand a non-finding, does the clear inability of the jury pool to make the necessary finding along rational lines do so pragmatically?

Really, it wouldn't matter if they jurors all held doctorates in the relevant field. If the goal is to determine with which of two conflicting reasonable opinions is unreasonable (which when you think about it is precisely what we ask jurors to do in evaluating expert testimony) the only possible answer is neither and therefore the point isn't proved adequately.

There is, of course, a reason the public sneers at expert testimony.  Don't believe they do?  Consider New Mexico where in 1995 a proposed amendment to a regulatory bill for psychologists was actually passed by the state senate.

When a psychologist or psychiatrist testifies during a defendant's competentcy hearing, the psychologist or psychiatrist shall wear a cone-shaped hat that is not less than two feet tall. The surface of the hat shall be imprinted with stars and lightning bolts.

Additionally, a psychologist or psychiatrist shall be required to don a white beard that is not less than 18 inches in length, and shall punctuate crucial elements of his testimony by stabbing the air with a wand. Whenever a psychologist or psychiatrist provides expert testimony regarding a defendant's competency, the bailiff shall contemporaneously dim the courtroom lights and administer two strikes to a Chinese gong.

Honest.

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* I was all set to do some snark about the weather.  In fact, I began with this:

I'm no fan of warm weather (once it hits 70 I want to put on the A/C), and I'm a big fan of cloud cover rather than sun (had god wanted us to be up and out during the day, she'd never have invented the light bulb).

Then I was going to say that living in Helsinki would be like living in a house we rented one fall semester in Pittsburgh when we were in college, back in the days of the ancien régime. Among other unlikely features, the place that had big holes in all the outside walls where the landlord really intended to put windows some day.  I remember one December night, wind whipping through the place, snow settling on the furniture, me sitting on the floor in front of the stove with the oven set at 500 and the door wide open to let some of the heat into the kitchen, bundled up in winter coat and gloves, typewriter before me, trying to type a paper.  Except I looked up Helsinki weather to stick in some numbers and it turns out that Helsinki actually has a pretty fair climate so the hell with it.

** I'm quoting Ohio although the standards differ from state to state and off to the feds, but Ohio's test is within striking distance of the others.

*** Reproduced here from Hart Seely's "The Poetry of D.H. Rumsfeld" at Slate.com.

As we know,
There are known knowns.
There are things we know we know.
We also know
There are known unknowns.
That is to say
We know there are some things
We do not know.
But there are also unknown unknowns,
The ones we don't know.

Meow, You Are Getting Sleepy

It's just the other day I was talking about mountebanks and charlatans and how we (by which I mean the police and the prosecutors and the judges and the jurors and even the defense counsel) rely on these so-called "experts" to tell us things they don't know or can't know or just make up.

Sometimes it turns out that these "experts" simply don't have the credentials they claim.

• Talibah Akili testified as an expert citing her multiple postgraduate college degrees and her certification as a social worker, forensic counselor and substance abuse counselor. Lies. Not stretchers, out and out lies.
• Raymond Cole gave three decades of what turns out to be meaningless testimony on the effects of alcohol on driving. His resume said that he had a degree from the University of California Berkeley in “Premedical Studies.” I'm not sure what premedical studies might be as a degree field. But it isn't political science which was his actual discipline.
• Dr. Faidherbe Ceus falsely claimed to be board certified in psychiatry.*

I could go on, but I won't.

Lawyers too rarely check. It's not that most seeming experts are lying on their CVs. They're not. But you don't want your client convicted because you didn't look into it. And the government doesn't really want dozens of cases blowing up on it because they were too lazy to make a credential-checking phone call. After all, there's pretty much always someone you can find who'll say what you want and actually has the claimed credentials.

How do I know that? About four years ago I paid something like $5.95 plus shipping and handling for a certificate that says I'm a certified "anti-terrorism expert." (Admittedly, it doesn't say who certified me, but that just gives me room to improvise.) And then there's this news (via Ken at Popehat).

George was registered with the British Board of Neuro Linguistic Programming (BBNLP), the United Fellowship of Hypnotherapists (UFH) and the Professional Hypnotherapy Practitioner Association (PHPA).

OK, they probably have lots of registered members. Few, however, are likely calico, of the species felix domesticus. Or, of course, maybe a whole lot are. And, after all,

A PHPA spokesman said the organisation makes great effort to ensure every applicant is a fully-qualified hypnotherapist.

I feel better already.

Of course, the good news is that I'm in the good old US of A, on the other side of the pond, where something like this couldn't happen. Except that an American clinical psychologist wasn't so sure.

Dr Steve Eichel suspected industry bodies in the US were not running checks on their members.

He said: "I felt I'd test my hypothesis and I did that by getting my cat certified by a number of the most prominent lay hypnosis organisations in the United States. It was a frighteningly simple process."

Ooops.

Then again, look at all those people who believed Bernie Madoff was doing a brilliant job investing their fortunes.

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*These and other tales of dishonest and fruadulent forensic experts can be found here.

EXPERTS

Three very interesting cases on experts and the like.

In People v. Safford, a divided panel of the Appellate Court of Illinois, First Division, reversed a conviction because the fingerprint evidence wasn't supported by a strong enough foundation. Specifically, the fingerprint examiner who testified that his analytic model was a matrix analysis, said that he used first, second, and third tier evaluations to compare a latent with a known print and conclude that they came frome the same person. But he didn't testify to just what he did at each stage of the analysis or how he did it.
Safford argued

The defendant contends the trial court erred in allowing Examiner Cutro to testify to his conclusion that the latent print recovered from Officer Marcano's patrol car belonged to the defendant without ever testifying, on either direct or crossexamination, to the evidentiary basis for his opinion. In his main brief, the defendant contends that to allow opinion testimony based solely on the qualifications of the witness as an expert, without disclosing the basis for the opinion "would be to invite forensic fraud." The defendant attacks the fingerprint identification testimony that the trial court allowed as equivalent to allowing Examiner Cutro "to testify in essence: I am an expert and you have to take my word for it." The defendant
argues the trial court erred by not requiring the State to offer an adequate foundation in the form of the expert's underlying reasoning to explain the expert's ultimate conclusion presented to the jury.

Under the circumstances, the court explained, there was simply no way for the defendant to conduct a meaningful cross-examination. In effect, the fingerprint examiner's testimony was no more than, "Trust me, I'm an expert." (Personally, and as an aside, I like to call these guys "trained lookers," butI digress.)

Still, you can see that the court might have let the purported "expert" get away with it if he'd tried. But

We can think of no reason Examiner Cutro could not explain the Level One, Level Two, and Level Three details he must have observed on each occasion, which led him to conclude that the two prints matched. "An expert's opinion is only as valid as the bases and reasons for the opinion." Gaytan, 313 Ill. App. 3d at 146. It was insufficient for Examiner Cutro to rely on his training and expertise as a basis for his ultimate opinion that no one other than the defendant could have left that latent print on Officer Marcano's police car. Before the jury could assess the weight and credibility of Examiner Cutro's opinion, it was incumbent on the trial judge to determine whether the foundational requirements had been met for the admission of Examiner Cutro's opinion. This was a question of law. "The trial court [may not] blindly accept the expert's assertion that his testimony has an adequate foundation." Gaytan, 313 Ill. App. 3d at 146.

Good for them.

Actually, Illinois is on a roll. A couple of weeks before Safford, another division of the appellate court there decided People v. Daniels, reversing the trial court's denial of a motion to suppress a confession. Why? Because Daniels didn't have the mental capacity to understand Miranda warnings.

Three experts testified. Two, in great detail, explained the testing they conducted and how and why and reached the conclusion that as a consequence of Daniels profound mental retardation she did not understand the warnings and, therefore, her waiver was not valid. The third expert disagreed. The trial court essentially discounted all of that.

After hearing all of the evidence and watching the videotaped confession, the circuit judge found defendant had knowingly and intelligently waived her rights. In doing so, the judge stated that he did not see how defendant’s poor performance on the abstract reasoning test applied to her ability to waive Miranda, noting that “as an intelligent person” he would have difficulty defining the similarities between “an ear and an eye” or explaining a proverb such as “between a rock and a hard place.” The judge further stated that defendant had received her rights at “every single turn” and that the experts’ opinions were a “wash” because the videotape of the confession “clearly indicate[d], without any doubt whatsoever, that [defendant] was advised of her rights, [that] she chose to give a statement, and [that] she did so knowing and understanding what her rights were.” The judge also found it unlikely that defendant would have said she understood something if she did not. The judge ultimately concluded that if a proverb was to be used to determine whether defendant had intelligently and knowingly waived her Miranda rights, then the following proverb should “be added to the mix: The truth is in the pudding,” with the pudding being defendant’s own videotaped confession.

We all know judges like that. Hell, we all appear before them regularly. What we all don't have is a court of appeals that

cannot find any basis upon which to predicate the transcendency of the judge’s lay opinion over that of the court’s own appointed experts . . . .

Rather the trial judge apparently chose to formulate his opinion based upon his own conceptualization of what it would take to establish sufficient comprehension of the import of Miranda warnings and chose to rely on defendant’s videotaped statement and her answers of “yes” to questions regarding her understanding of Miranda warnings without probing into defendant’s ability to understand the questions to which her answers were directed.

It's pretty damning.

Finally, there's the U.S. District Court for the Middle District of Alabama which, after trial, issued an opinion exploring numerous problems with eyewitness identification testimony and explaining why it allowed a defense expert (Solomon Fulero) to testify about eyewitness identification in general but not about the specific witnesses in the case (United States v. Smith, No. 07cr165).

No quotes this time. Just read it.