Pyles v. Weaver

Kimberly Pyles (plaintiff) worked as a dancer at a gentlemen’s club operated by Rick’s Cabaret (Rick’s) (defendant). One evening, as Pyles was dancing on stage at the club, Anthony Weaver (defendant) approached Pyles and offered her a dollar if she would expose her body. Pyles cut her routine short and left the stage. As Pyles was walking to report Weaver to the club’s host, Weaver threw a heavy glass at Pyles’s face, injuring Pyles. Pyles sued Rick’s and Weaver to recover for her injuries. Pyles alleged, in part, that Rick’s negligently failed to provide adequate security to protect her. At trial, Pyles called Larry Preston Williams to give expert testimony on whether Rick’s had effective security. Williams testified that he had a bachelor’s degree in criminology, had worked for the New Orleans Police Department and been a special investigator for the district attorney’s office, and had published articles and given lectures on violence protection and protective measures. However, Williams was not certified in protection, did not belong to any organizations of security professionals, had never testified as an expert on nightclub security, and had never designed or analyzed security for gentlemen’s clubs, bars, or nightclubs. Williams had a law license, but his license had been revoked for misconduct. The trial court accepted Williams as an expert based on Williams’s law-enforcement and security-related experience. Williams opined that Rick’s did not have adequate security and that the lack of security contributed to Pyles’s injury. Rick’s countered Williams’s testimony with testimony from its own security expert, who had more security expertise than Williams. The jury ultimately found in Pyles’s favor. Rick’s appealed, arguing that Williams was not qualified to testify as a security expert.